Food Logistics April 2017

SPECIAL EDITION: FOOD SAFETY MODERNIZATION ACT

Food Logistics

FOOD DEFENSE PLANNING

INDUSTRY PUTS PROTECTIONS IN PLACE TO DEFEND FOOD SECURITY

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Global Supply Chain Solutions for the Food and Beverage Industry

FSMA THE RULES ARE BLACK AND WHITE

DECADES OF OPERATING IN THE GRAY AREA GIVES WAY TO A RULES-BASED SYSTEM DESIGNED TO SIGNIFICANTLY IMPROVE FOOD SAFETY.

Issue No. 185 April 2017 FoodLogistics.com

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ON THE MENU

ON THE MENU

OCTOBER 2015 ISSUE NO. 171

April 2017 ISSUE NO. 185

18 COVER STORY

A NEW ERA ARRIVES A milestone in U.S. food safety legislation is distributing responsibility throughout the supply chain and strictly enforcing accountability.

COLUMNS FOR STARTERS

T he RAA Doesn’t Pass the Smell Test

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Uncertainty surrounds the Food Safety Modernization Act as Congress begins a rollout of the Regulatory Accountability Act. COOL INSIGHTS

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S anitary Transportation of Food Brief

Don Durm, vice president of customer solutions at PLM Trailer Leasing, shares guidelines on the Food Safety Modernization Act’s Sanitary Transportation of Food regulation.

FOOD (AND MORE) FOR THOUGHT

42

N o Rules?

No Food Safety

Food safety rules are likely to fall victim to the recently passed Regulatory Accountability Act, which some are labeling the “filthy food bill.”

DEPARTMENTS

Supply Scan

8 12

Food on the Move

41

Ad Index

WEB EXCLUSIVES

FEATURES SPECIAL REPORT

34

F ood Defense Planning—For What Purpose?

Food and beverage companies can learn a thing or two from the United States Army when creating a food defense plan.

SPECIAL REPORT

38

hytosanitary and Logistics Communities P Converge on Food Safety Issues

Chapman University forum brings together interests from all sides.

• Q&A: Cargo Theft in the Food and Beverage Industry foodlogistics.com/12320013

• Cracking the Code—From Food Safety to Consumer Engagement foodlogistics.com/12315365

• Food Logistics’ Educational Webinar Series foodlogistics.com/webinars

Published and copyrighted 2017 by AC Business Media Inc. All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopy, recording or any information storage or retrieval system, without written permission from the publisher.

Food Logistics (USPS 015-667; ISSN 1094-7450 print; ISSN 1930-7527 online) is published 10 times per year in January/February, March, April, May, June, July, August, September, October and November/December by AC Business Media Inc., 201 N. Main Street, Fort Atkinson, WI 53538. Periodicals postage paid at Fort Atkinson, WI 53538 and additional mailing offices.

POSTMASTER: Send address changes to Food Logistics, P.O. Box 3605, Northbrook, IL 60065-3605. Canada Post PM40612608. Return undeliverable Canadian addresses to: Food Logistics, Station A, P. O. Box 25542, London, ON N6C 6B2. Subscriptions: U.S., one year, $45; two years, $85; Canada & Mexico, one year, $65; two years, $120; international, one year, $95; two years, $180. All subscriptions must be paid in U.S. funds, drawn from a U.S. bank. Printed in the USA.

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FOOD LOGISTICS | APRIL 2017

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FOR STARTERS

FROM THE EDITOR’S DESK

THE RAA DOESN’T PASS THE SMELL TEST

T SOWINSKI

Congressman Bob Goodlatte (R-Va.), Chairman of the House Judiciary Committee, introduced the Regulatory Accountability Act of 2017 on Jan. 3.

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he Food and Drug Administration’s (FDA) Food Safety Modernization Act (FSMA) was signed into law in January 2011, and since then, we’ve seen a steady rollout and systematic finalization of its seven primary regulations.

On April 6, one of those regulations, the Sanitary Transportation of Human and Animal Food, entered the enforcement stage. This is a big deal for our industry and American consumers.

Food growers, manufacturers, transporters, distributors and others affected by this regulation— and others in the global food supply chain impacted by the remaining six regulations that comprise the FSMA—invested significantly to train and educate staff and supply chain partners; purchase and update equipment, software, temperature-monitoring devices and other tools; and overhaul standard operating procedures (SOP) and processes to assure they are in compliance with this historic legislation.

A new uncertainty has arisen, however.

The Regulatory Accountability Act (RAA) of 2017, disparagingly termed the “filthy food bill” by some food safety proponents, has the potential to diminish progress on the food safety front just when

FOOD LOGISTICS | APRIL 2017

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efforts to galvanize food safety are starting to formally coalesce under the FSMA. The House of Representatives bill dubbed RAA, sponsored by Rep. Bob Goodlatte (R-Va.), was passed Jan. 11. The Senate bill by the same name, sponsored by Sen. Rob Portman (R-Ohio), was recently scheduled for markup by the Senate Homeland Security and Governmental Affairs Committee on March 15, before it was pulled off the schedule. The bill was not yet made available to the public.

Scott Faber, vice president of government affairs for the Environmental Working Group (who formerly served the Grocery Manufacturers Association as vice president for federal affairs where he spearheaded efforts to enact the FSMA), writes about how this bill could turn into a genuine setback for food safety in this month’s Food (and More) for Thought column on Page 42 of the magazine.

Meanwhile, this special edition of Food Logistics looks at the FSMA and food safety from a number of angles, all of which help reveal the level of preparedness—and gaps— that exist as our industry enters this new era of food safety.

Enjoy the read.

LARA L. SOWINSKI, EDITORIAL DIRECTOR LSOWINSKI@ACBUSINESSMEDIA.COM

DETAILS

Published by AC BUSINESS MEDIA INC. 201 N. Main Street, Fort Atkinson, WI 53538 (800) 538-5544 • www.ACBusinessMedia.com

WWW.FOODLOGISTICS.COM PRINT AND DIGITAL STAFF Group Publisher Jolene Gulley Associate Publisher Judy Welp Editorial Director Lara L. Sowinski lsowinski@ACBusinessMedia.com Editor Ronnie Garrett rgarrett@ACBusinessMedia.com Managing Editor Carrie Mantey cmantey@ACBusinessMedia.com Assistant Editor Amy Wunderlin awunderlin@ACBusinessMedia.com Senior Production Manager Cindy Rusch crusch@ACBusinessMedia.com Creative Director Kirsten Crock Sr. Audience Development Manager Wendy Chady Audience Development Manager Angela Kelty ADVERTISING SALES (800) 538-5544 Associate Publisher (East Coast) Judy Welp (480) 821-1093 jwelp@ACBusinessMedia.com Sales Manager (Midwest and West Coast) Carrie Konopacki (920) 542-1236 ckonopacki@ACBusinessMedia.com National Automotive Sales Tom Lutzke (630) 484-8040, tlutzke@ACBusinessMedia.com EDITORIAL ADVISORY BOARD Jaymie Forrest, Chief Supply Chain and Commercial Officer, ScanTech Sciences Inc. John Haggerty, Vice President of Business Development, Burris Logistics Robert A. Norton, Ph.D., Professor of Veterinary Microbiology, Public Health and Biosecurity, Auburn University; Coordinator of National Security Initiatives, The Futures Laboratory Jon Shaw, Director of Sustainability and Global Marketing Communications, UTC Climate, Controls & Security Smitha G. Stansbury, Partner, FDA & Life Sciences Practice, King & Spalding CIRCULATION & SUBSCRIPTIONS P.O. Box 3605, Northbrook, IL 60065-3605 (877) 201-3915, Fax: (800) 543-5055 circ.FoodLogistics@omeda.com LIST RENTAL Elizabeth Jackson, Merit Direct LLC (847) 492-1350, ext. 18; Fax: (847) 492-0085 ejackson@meritdirect.com REPRINT SERVICES Carrie Konopacki (920) 542-1236 Fax: (920) 542-1133 ckonopacki@ACBusinessMedia.com AC BUSINESS MEDIA INC. Chairman Anil Narang President and CEO Carl Wistreich Executive Vice President Kris Flitcroft CFO JoAnn Breuchel Vice President of Content Greg Udelhofen Vice President of Marketing Debbie George Digital Operations Manager Nick Raether Digital Sales Manager Monique Terrazas

Published and copyrighted 2017 by AC Business Media Inc. All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopy, recording, or any information storage or retrieval system, without written permission from the publisher.

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SUPPLY SCAN

NEWS FROM ACROSS THE FOOD SUPPLY CHAIN Daily Updates at FoodLogistics.com

TESCO UNVEILS NEW SERVICE TO MINIMIZE FOOD SUPPLY CHAIN WASTE

Tesco launched an online food waste hotline to help make it easier for suppliers and growers to pinpoint ongoing food waste hotspots, and work with retailers in tackling them.

The service will link suppliers to Tesco’s product teams and will be accessible via the online Tesco Supplier Network. The British multinational grocery and general merchandise retailer pointed to last summer’s strawberry glut, which it responded to by stocking larger punnet sizes at competitive prices, as an example of how waste can be avoided in the chain through prompt action. “We are committed to reducing food waste wherever it occurs, from farm to fork, and the hotline is another little [tool] we are making to achieve this with our suppliers,” says Matt Simister, commercial director for fresh food and commodities. “It helps our suppliers gain direct, easy access to our product teams, and enables us to identify food waste hotspots and systemic issues, and work in partnership to tackle them.”

Tesco made a commitment that no surplus food be wasted in its United Kingdom operations by the end of this year.

U.S. SENATOR CALLS FOR IMPORT BAN FOLLOWING REPORTS OF ROTTEN MEAT

Montana State Sen. Jon Tester introduced a bill to temporarily ban Brazilian beef imports into the United States, following reports that Brazilian meat packers were exporting rotten beef by bribing inspectors and trying to cover it up with cancer-causing acid products.

Tester’s legislation will place a 120-day ban on Brazilian beef imports, giving the U.S. Department of Agriculture time to comprehensively investigate food safety threats and determine which Brazilian beef sources put American consumers at risk.

The European Union, China, South Korea and Chile already banned imports of Brazilian beef.

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FOOD LOGISTICS | APRIL 2017

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YCH GROUP TEAMS WITH KUNMING FOR COLD CHAIN DEAL

YCH Group will partner with Kunming Airport Cold Chain Logistics Industry to establish a cold chain facility across 175 acres of land to provide southwestern China with cold chain logistics support. The key focus of this collaboration is to create a platform for international procurement and cold chain logistics.

The initiative is timely, as the value of social logistics goods in 2016 expanded by 6.1 percent year over year to $33.2 trillion, and the National Development and Reform Commission in Singapore encouraged sophisticated development of the logistics sector over the next five years to boost China’s economic growth and deepen supply-side reform.

Value of Social Logistics Strategically located in close proximGoods in 2016 ity to both the Kunming Airport and a multipurpose transport hub, the facility will position Kunming as an agricultural production hub through the leveraging of cold chain technologies to reduce the loss of produce, while increasing food safety and security.

Featuring an ambient temperature distribution component to complement the cold chain facility, it will handle imported chilled and frozen products from the South Pacific and Association of Southeast Asian Nations (ASEAN) regions into Kunming for distribution via southwestern China into its southern and western regions. It also can be used as an export facility to distribute Yunnan produce, such as fruits and flowers, to European markets.

“We are increasing our focus on the cold chain due to growing market demand in the Asia-Pacific region,” says Dave Lim, CEO of YCH China. “This collaboration will enable us to enhance the logistics capabilities of southwestern China with state-of-the-art facilities, enabling distribution of cold chain supply to Yunnan and other parts of China.”

This collaboration will help better serve the growing demand for cold chain logistics in the region, providing increased scalability and flexibility for the growing consumer market in China.

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SCOTT GOTTLIEB IS TRUMP’S CHOICE FOR FDA COMMISSIONER

Scott Gottlieb, a practicing physician and resident fellow at the American Enterprise Institute (AEI), is President Donald J. Trump’s pick to be the 23rd commissioner of the Food and Drug Administration (FDA).

He was the FDA’s deputy commissioner for medical and scientific affairs from 2005 to 2007.

Gottlieb is one of the nation’s foremost voices for “changing the FDA’s culture.” His views on issues are easy enough to find as he’s been putting them out there for the AEI and in national periodicals for the past decade.

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SUPPLY SCAN

NEWS FROM ACROSS THE FOOD SUPPLY CHAIN Daily Updates at FoodLogistics.com

YALE EXPANDS DRIVEN BY BALYO ROBOTIC LIFT TRUCK LINEUP

For supply chain operations striving to meet faster delivery expectations, while dealing with labor availability and retention challenges, Yale offers a new addition to its automation lineup. The Yale MO70T tow tractor now joins the company’s MPE080VG end rider model, using Driven by Balyo technology to autonomously navigate through warehouse environments and execute mission-critical load transportation tasks.

Ideal for sequencing applications in assembly operations and stock replenishment, the MO70T is the second robotic solution available since Yale partnered its materials-handling expertise with Balyo’s navigation technology. Both the tow tractor and end rider solutions use infrastructure-free navigation technology that maps existing structural features to self-locate and navigate without requiring tape, wires or magnets for guidance.

This enables reduced startup time and costs, and easy adjustment to changing layout configurations.

“The addition of the flexible Driven by Balyo technology to the tow tractor model provides a scalable robotic solution for multiple load transportation applications,” says Lou Micheletto, manager of integrated solutions for Yale. “Whether a single truck or large fleet, the expanded autonomous lift truck lineup allows operations to reap the benefits of greater load visibility, reduced operating costs and increased reliability.”

COLD CHAIN MARKET EXPECTED TO MATURE THANKS TO GROWING CONSUMER-LED ECONOMY The global cold chain market is anticipated to reach $381.68 billion by 2025, according to a new report by Grand View Research Inc. The development of the cold chain is largely responsible for reducing the waste of perishable commodities and is vital for the growth of the food sector. The report says, over the next few years, more governments across the globe are expected to provide key services, such as public infrastructure and legislation, to help facilitate refrigerated storage development.

As emerging countries, such as India, Brazil, China and Mexico, undergo a rapid transition to a consumer-led economy, the demand for better cold chain logistics will increase. The retailers in these regions have ample opportunities to expand and grow, owing to the prevailing number of middle-class income consumers. Advancements in technology are also enabling service providers to penetrate emerging markets with innovative solutions to help solve issues relating to complex transportation.

The report notes that another factor affecting cold chain growth is increased investment in warehouse automation to meet customer requirements. High capital investment, running costs and scalability of different picking methods are the key factors restraining market players from automating their warehouses. Furthermore, the growing application of telematics in logistics and transportation is likely to spur refrigerated transportation market demand.

Additionally, the report says that increased penetration of connected devices and growing usage of RFID barcode scanners in the refrigerated warehouse are anticipated to drive the monitoring components segment demand over the projected period.

Service providers are focusing on adopting new technologies, such as the cloud, to enhance overall logistics performance.

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FOOD LOGISTICS | APRIL 2017

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FDA TO CONSIDER SIMPLER AGRICULTURAL WATER STANDARDS

The U.S. FDA is exploring ways to simplify the microbial quality and testing requirements for agricultural water established by the Food Safety Modernization Act’s (FSMA’s) produce safety rule, while still protecting public health.

Agricultural water can be a major conduit for pathogens to contaminate produce. That is why the FSMA’s produce safety rule sets microbial quality standards for agricultural water, including irrigation water that comes into contact with produce.

However, the feedback the FDA received is that some of these standards may be too complex to understand, translate and implement. These factors can be important in achieving high rates of compliance. In response to these concerns, the FDA is considering how it might simplify the water standards. It intends to work with stakeholders as these efforts related to the water standards proceed.

SAP ARIBA ENTERS BLOCKCHAIN GAME WITH EVERLEDGER

SAP Ariba unveiled plans to leverage blockchain across its cloudbased applications and business network to upend the way goods and services are traded. Through a joint effort with Everledger, a fintech company, the U.S. software and IT firm owned by tech giant SAP plans to extend such capabilities to the entire Ariba Network.

At its core, the blockchain is a digital ledger that can be used to drive business processes involving multiple parties. “One of the things blockchain does is facilitate greater visibility and trust,” says Joe Fox, senior vice president of business development and strategy, SAP Ariba. “In embedding it across our network, we can enable supply chains that are smarter, faster and more transparent from sourcing all the way through settlement.”

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FOOD ON THE MOVE

LOGISTICS TRENDS IN OUR INDUSTRY

WELLDOC AND THE HEALTHY TRUCKING ASSOCIATION OF AMERICA PARTNER TO ADDRESS DIABETES Digital health leader WellDoc and the Healthy Trucking Association of America (HTAA) will partner to help truckers living with diabetes through WellDoc’s consumer diabetes health app, BlueStar C, which is designed to aid individuals living with diabetes to manage their chronic condition.

“The trucking industry is facing a severe health crisis due to the prevalence of diabetes, and we are passionate about providing a solution to help individuals manage their diabetes. BlueStar C is geared for people like truckers, who lead hectic and busy lives. Our product can support them on their diabetes health journey,” says Kevin McRaith, CEO of WellDoc. According to the National Survey of Long-Haul Truck Driver Health and Injury conducted by the National Institute for Occupational Safety and Health (NIOSH), over two-thirds of respondents were obese (69 percent), and 17 percent were morbidly obese. Obesity increases the chance for type 2 diabetes, sleep apnea, heart disease, cancer,

joint and back pain and stroke. The prevalence of diabetes among truck drivers was more than twice that of the general population (14 percent versus 7 percent).

“Diabetes and its related complications can disqualify drivers from receiving or maintaining their commercial driver’s license—ultimately taking away their livelihood. We believe BlueStar C will truly help truckers stay on track with their diabetes self-care, both on and off the road,” adds Bill Gordon, president and CEO of HTAA. WellDoc’s digital therapeutic app supports the lifestyle changes and all medication regimens that people with diabetes are often prescribed.

Additionally, the user data are summarized and shared with health care providers to assist in clinical decision-making. BlueStar C helps users track and share their diabetes self-management data with their families, caregivers and health care teams.

DAT SOLUTIONS’ MONTHLY FREIGHT REPORT

Strong February Spot Truckload Volumes, Rates Rise at Month’s End Mark Montague is industry rate analyst for DAT Solutions, which operates the DAT network of load boards and RateView rate-analysis tool.

He has applied his expertise to logistics, rates, and routing for more than 30 years. He is based in Portland, Oregon.

For information, visit www.dat.com.

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Total freight volume was 48 percent higher last month than in February 2016, although the DAT North American Freight Index fell 13 percent, and spot truckload rates softened in February compared to January. An influx of capacity from contract carriers held down spot van and refrigerated freight rates.

“Volume on the spot market in February was robust for what is traditionally a slow month for freight,” says Don Thornton, senior vice president, DAT Solutions, which operates the industry’s largest on-demand freight exchange for spot truckload freight. “The strong freight volumes attracted an unusual number of contract carriers, and the added capacity helped keep rates down on many hightraffic van and reefer lanes until late in February, when national average contract rates began to firm up.”

FOOD LOGISTICS | APRIL 2017

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By Mark Montague

Compared to January, the national average spot van rate was $1.62 per mile, including a fuel surcharge, down 5 cents, while the average reefer rate was $1.86 per mile, down 9 cents. However, by the last week of February, load-totruck ratios were up sharply and spot rates had increased week over week.

Although month-overmonth spot van and reefer load posts declined in February, demand for flatbed trucks rose 27 percent. The flatbed load-to-truck ratio was 26.6, meaning there were 26.6 available flatbed loads for each truck on the DAT network. “Flatbed freight includes building materials and heavy machinery,” Thornton says. “High volume indicates activity in construction and energy sectors in particular, as drillers take advantage of crude prices that have been mostly over $50 a barrel since OPEC agreed to cut supplies in late November.” The national average spot flatbed rate was $1.96 per mile, 4 cents higher than in January.

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FOOD ON THE MOVE

LOGISTICS TRENDS IN OUR INDUSTRY

OHIO LAWMAKERS ADDRESS DRIVER SHORTAGE Ohio lawmakers launched a four-part plan last month to help trucking companies fill thousands of job openings. A series of bills was introduced addressing problems that have put the industry in crisis.

Lawmakers say there aren’t enough people interested in the profession, and changes are needed to help the industry attract new talent. Changes proposed in the legislation include reduced age restrictions for insurance coverage, providing scholarships and loans to those who attend truck driver schools, and tax credits of up to $25,000 to companies that provide on-the-job training programs for drivers.

The changes are backed by the industry.

EUROPEAN COMMISSION FINES LEADING AIR CARRIERS FOR PRICE FIXING

The European Commission (EC) has readopted a decision against leading air cargo carriers for their involvement in a price-fixing cartel from December 1999 to February 2006, covering flights within the European Economic Area.

The cartel arrangements consisted of numerous contacts between airlines, at both bilateral and multilateral levels to fix the level of fuel and security surcharges.

Carriers involved in the scandal included: Air Canada, Air France, KLM, Martinair, British Airways, Cargolux, Cathay Pacific Airways, Japan Airlines, LAN Chile (now LATAM), SAS, Singapore Airlines, Lufthansa, Swiss International Air Lines and Qantas.

All companies except Qantas appealed to the EU’s General Court against the 2010 decision, which ended up being annulled on procedural grounds in 2015. As a result, the decision became final for Qantas.

However, the General Court did not rule on the existence of the cartel, and the EC has now decided to bring operative aspects of the case in line with the reasoning part, thus reactivating the fines with some reductions under a leniency notice.

Lufthansa and its subsidiary Swiss International Air Lines have received full immunity from the fines.

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FOOD ON THE MOVE

LOGISTICS TRENDS IN OUR INDUSTRY

PANAMA CANAL EXPANSION BOOSTS PORT OF SAVANNAH SHIPMENTS Cargo shipments to the Port of Savannah in Georgia rose 10 percent in February, reaching an all-time high as the widened Panama Canal continued to boost the number and size of ships headed for U.S. East Coast ports.

The Panama Canal expansion was completed in June, and next year, northwest Georgia and other nearby markets should also benefit with the planned opening of the Appalachian Regional Port for the CSX Railroad near Chatsworth, Georgia.

The Georgia Ports Authority reports that it moved 2.94 million tons across all docks at the Port of Savannah in February, second only to January’s 3.01 million tons during a month with three more days.

“Ocean carriers have recognized the Port of Savannah as the must-call port to serve the Southeastern U.S.,” GPA Executive Director Griff Lynch tells the Authority Board. “With the coming realignment of the shipping alliances in April, Savannah will offer more container services than any other East Coast or Gulf port, at 35 weekly vessel calls.”

Container tonnage was a leading factor in the growth, expanding by 14.4 percent (314,832 tons) to more than 2.5 million tons for the month.

Next year, some of those shipments are likely to head toward the Chattanooga region, when a direct, 388-mile rail route to the Georgia Ports Authority’s Garden City Terminal is opened.

The $24 million facility will open by 2018, with a capacity of 50,000 containers per year. A 10-year development plan will then double that capacity.

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APRIL 2017 | FOOD LOGISTICS

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COOL INSIGHTS

BY DON DURM

SANITARY TRANSPORTATION of Food Brief D on Durm, vice president of customer solutions at PLM Trailer Leasing, is a true asset to the food logistics community. His efforts to raise awareness and knowledge about the Food Safety Modernization Act (FSMA), and Sanitary Transportation of Food (STF) regulation in particular, are helping many in the industry. He shared the following guidelines with Food Logistics for this month’s special edition.

DURM

The Sanitary Transportation of Food FSMA enables the Food and Drug Administration (FDA) to focus more on preventing food safety problems rather than relying primarily on reacting to problems after they occur.

The FDA’s final STF rule, which is nearly 300 pages in length, was published April 6, 2016, and will become enforceable April 7, 2017, for most businesses.

Industry Position Within the STF rule, the FDA defined regulatory roles for the shipper, loader, carrier and receiver, but more directly, identified the shipper as the key stakeholder charged with the responsibility of keeping food safe during transport by rail and/or motor carrier. Deliverable requirements will change by the role that the refrigerated transport company plays within the distribution channel.

If your role is the shipper, loader and carrier, you can accomplish all the written record requirements through a written internal standard operating procedure (SOP) that is maintained for a period of one year beyond their use. If your role is only the shipper, you are responsible

Within the STF rule, the FDA identified the shipper as the key stakeholder charged with the responsibility of keeping food safe during transport by rail and/or motor carrier.

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for delivering in writing all the requirements to keep food safe during transport, which needs to be maintained for one year beyond their last use, to the carrier.

Written Requirements Trailer Specification & Design Compliance: Trailer design and construction should be made of materials that are cleanable to maintain sanitary conditions to ensure the safe transport of food.

Sanitization Compliance: Develop sanitation procedures for the different load types and frequency for food vehicles to ensure all food-contact surfaces are safe to prevent cross-contamination during the loading, transportation and unloading phase.

Temperature Compliance: Develop any necessary pre-cooling requirements for the load that are specific by commodity types.

Document any temperature control requirements during transport, which may include any temperature records and data exchange requirements that the shipper and/ or receiver may require.

Carrier Training Compliance: Carriers are required to provide driver training for food safety education that includes safe food handling for the commodities transported. Required documentation is the name of the driver trained, the date of training and what the training included. The training is provided upon employment, and the record must be maintained for

one year beyond the last activity of the job function.

Regulatory Engagement • Review to ensure current fleet trailer specification and design satisfy regulatory shipper requirements as to the construction of materials that keep food safe during transport.

• Review current trailer sanitation protocols by type and frequency, and maintain in writing as required by rule.

• Review current procedures for pre-cool activity to ensure safe food handling before loading.

These must be in writing.

• Review current temperature profiles to ensure safe transport of food commodities and how that should be communicated to the carrier, and maintain the protocol record for one year.

• Train drivers by commodity types to ensure safe transport of temperature-controlled products. Carrier must maintain this record for a period of one year beyond their last activity in the job function.

• The FDA indicated it is going to rely on industry best practices.

Conduct a gap analysis on written protocols from the International Refrigerated Transportation Association Best Practices Guide, available at the Global Cold Chain Alliance’s websitewww.gcca.org.

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4/5/17 1:29 PM

COVER STORY A milestone in U.S. food safety legislation is distributing responsibility throughout the supply chain and strictly enforcing accountability.

BY LARA L. SOWINSKI

A

re we prepared for the Food Safety Modernization Act (FSMA)? What should we feel confident about and where are the gaps? Those were the questions I wanted answered as I started to work on this special edition devoted to this landmark legislation.

The idea is to provide a candid glimpse into how our industry is responding to the FSMA. I believe this is valuable—and necessary. While most of us invested considerable time and resources in educating ourselves and our organizations about the FSMA by staying on top

of the Food and Drug Administration’s (FDA’s) rulemaking process and reading in-depth legal analysis, there also is value in learning from others to see how they are navigating this new era in food safety.

On the following pages, you’ll find the responses to a handful of FSMA-related questions I posed, including a sidebar on integrating safety compliance in food and beverage operations.

In addition, two of our editorial advisory board members—Dr. Robert A. Norton, professor at Auburn University, and Jaymie Forrest, chief supply chain and commercial officer at ScanTech Sciences Inc.—contribute their insights and perspective.

V I R R A A R E W E N A THE IMPORTANCE OF FSMA ON THE FOOD SUPPLY CHAIN

68% companies

of leading food & beverage

are currently building compliance and traceability systems into their production processes.

Research from Sparta Systems

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TECHNOLOGY

Implementing the right technology into your supply chain can streamline current processes and set up your business for growth. To achieve compliance, companies should: automate tedious and manual processes, such as audits and supplier management, update enterprise IT infrastructure, and leverage cloud-based technologies. www.foodlogistics.com

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60.8% of consumers report substantial concern about food safety.

TOP REASONS CONSUMERS LEAVE A COMPANY Research from Accenture

Research from Hahn Public Communications

85%

reponded a company that doesn’t make it easy to do business.

IVES

①

84%

said promising one thing and delivering another.

58%

replied inconsistent experiences from channel to channel.

CUSTOMER TRUST & COMMUNICATION

Customer brand loyalty is at an alltime low in the rapidly increasing switching economy, which has grown to $1.7 trillion, according to an Accenture Customer 2020 study. Publicly pinpointing the source of the contamination, and effectively demonstrating the steps taken to ensure the cause has been rectified, allows the supplier to rebuild trust and display the ability to help prevent future outbreaks.

②

TRANSPARENCY

Transparency in the supply chain is no longer just a matter of ensuring efficiency and productivity-it is a regulated and market-driven necessity. The FSMA requires those in the food and beverage industry to focus on prevention rather than response to contamination incidents.

Without the ability to track and trace throughout the supply chain, it is impossible to achieve this goal.

③

$10 Million

is the average cost of a recall to a food company.

Research from the Food Marketing Institute and Grocery Manufacturers Association

FOOD SAFETY

U.S. Centers for Disease Control and Prevention estimate that foodborne illnesses affect nearly 48 million people (one in six Americans) per year, and account for more than 128,000 hospitalizations and 3,000 U.S. deaths each year.

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$77.7 Billion was the economic burden of recalls in 2012.

Research from Ohio State University

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COVER STORY continued

Q: WHAT IS YOUR

COMPANY’S ROLE IN THE FOOD SUPPLY CHAIN, AND HOW IS THE FSMA AFFECTING YOUR STRATEGY AND OPERATIONS? HOW IS IT AFFECTING YOUR CUSTOMERS?

A:

“When we’re transporting food products for our customers, we’re following the tenets of the FSMA,” emphasizes Tom Scollard, vice president of dedicated contract carriage, Penske Logistics.

“That typically includes transporting products from ← McCloud Services made manufacturers to distribution sure its pest management centers and to programs were the retail point FSMA-compliof sale. Penske ant before the legislation was Logistics advises our customers on enacted. good distribution practices and works closely with them to ensure they always remain within compliance. Advances in telematics technology are making compliance easier, with the ease of monitoring trailer temperatures serving as a good example.”

Patricia Hottel, technical director at McCloud Services, says that, as a

❶

pest management provider, the company plays a role in FSMA compliance by reducing the risks of pests to food safety. It stayed ahead of the curve by making sure its pest management programs were FSMA-compliant before the legislation was enacted. McCloud continued to strengthen programs to align with the FSMA, she says, “mainly in terms of language, documentation and staff training, which were completed and continue to be examined for improvements.”

For example, “Documentation regarding competency of those performing risk analysis is now included in the client documentation information on file at the client’s site. We are continually looking at ways to strengthen the format of documentation for risk analysis and preventive controls compliance.

We are also seeing an increase in requests from our clients for training of their staff members in pests and the risks they present to food safety. Training is something that we can provide and find mutually beneficial,” says Hottel.

Jerry Robertson, CTO of BOLT System, says: “We track freight as the first element of our hosted fleet management software. We believe it is our responsibility to enable our food distribution customers to electronically record and document aspects of their work governed by FSMA restrictions, and their shippers’ cargo-handling specifications.”

According to Robertson, “When we started developing our fleet

PREVENTIVE CONTROLS FOR HUMAN FOOD

This regulation sets standards for firms that manufacture, process, pack or hold human food, including produce businesses throughout the supply chain that are FDA-registered facilities and fresh-cut processors. The regulation requires such firms to have written plans that identify hazards, specify the steps that will be put in place to minimize or prevent those hazards, identify monitoring procedures and record monitoring results, and specify what actions will be taken to correct problems that arise.

COMPLIANCE DATE: SEPT. 19, 2016

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COVER STORY continued

process by which “all metrics from any past shipment are routinely captured, recorded and reportmanagement system, we worked on ed. While our fleet management system provides them those providing our customers the ability to monitor and track cargo, and capabilities, our customers must provide that information to their still ensure their drivers, managers, shippers in real time while it’s in dispatchers and office support staff transit. Since shippers are ultimateare well-versed in how to meet the ly responsible for their products new FSMA regulations with those throughout the entire supply chain, capabilities,” says Robertson. we knew they would require carriElizabeth Sinclair, a vertical ers to provide information on cargo marketing manager at Seagull conditions in transit or risk losing Scientific, maker of BarTender, their business to those who can.” the enterprise labeling software He adds, “Long before the FSMA that creates barcode and RFID went into effect, we saw cargo labels, explains, “We actually see monitoring and tracking capabilthe FSMA as a great opportunity ities as mission-critical for food for our food production, logistics distributors and other transportaand distribution customers to tion companies. So when the FSMA take a good long look at their data was enacted, our system provided management practices and internal customers the capability to manage processes. Many of them are not only temperature requirefinding that, by connecting internal ments, but also all elements relative systems, enabling a single source of to food safety.” truth and leveraging the power of BOLT System’s customers are their labeling software to manage having to focus on developing a variable data, they’re capturing new efficiencies that streamline their operations and cut costs.”

Christopher Hoemeke, vice president of agriculture and food services, Bureau Veritas North America, also sees the positive aspects of the FSMA. “Bureau Veritas’ Intralogistics has never been so simple role is to provide traceabilSystem Logistics and Vertique are now one company ity, visibility and safety for the supply chain through our testing, inspection and verification services.

Offering tailor made solutions for warehousing, ASRS, Quality and safety are an order picking systems and material handling. Our absolute priority for food focus is Food and Beverage with the install base that processors, retailers and restaurateurs for whom ranks us the leaders in our market. Allow our team to a single incident can have learn about your business and become a trusted a devastating impact on partner for your automated solutions. reputation and revenue,” he says.

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Second, we work with the food processing customer to analyze and certify the product they produce meets FSMA and Foreign Supplier Verification Program (FSVP) standards, if international, before it is distributed to thousands of grocers, restaurants and retail chains.

“For example, in 2015, one of the world’s largest tuna trading companies in Asia employed Bureau Veritas to verify the traceability of its tuna supply before it was shipped to a cannery facility. The verification program focused on ensuring there was no use of fish aggregating devices (FADs), a man-made object commonly used to attract tuna, in the supply chain. The certifier examined 30 large fishing vessels in the Pacific Ocean, transshipment to 20 carrier vessels and discharge to a Bangkok port. After the assessment was complete, a FAD-free traceability standard was set into place. And today, the Long before supply chain the FSMA went remains into effect, we saw consistently monitoring monitored and tracking to ensure capabilities as compliance is mission-critical for maintained. food distributors.”

Tuna suppliJerry Robertson, ers who meet BOLT System the FAD-free standard requirements receive a certificate of recognition to verify their compliance in Asia and to other international customers that require it.”

Finally, “Once the product arrives at a restaurant and retail chain, Bureau Veritas then works with that customer to help manage their food safety program. This sector collects thousands of pieces of data each week about its food.

This information focuses principally on food safety and quality, but also covers brand conformity, such as hospitality standards that define the customer experience. The problem is that many organizations still collect this information on paper, with no effective way of tracing or tracking data. Third-party audits www.foodlogistics.com

4/3/17 11:39 AM

help weed out problems. However, the vast majority of sites are compliant. This means a large proportion of companies’ audit budgets are focused on the wrong sites. “ Last July, the company launched a new digital service called SAFEOPS to help food retailers and restaurateurs manage food safety and operations effectively and cost-efficiently, he adds.

❷

“It provides customers an easy way to collect and track daily data at every site in real time, identify issues and address them rapidly. It helps our clients with profiling risks and saves money by avoiding a blanket approach to auditing, instead channeling spend where it is truly needed,” he says.

According to Hoemeke, “Our holistic food safety solutions are

100 percent FSMA-ready. Essentially, Bureau Veritas touches every point of the supply chain, starting with sea or farm to processing facility to plate … ensuring customers authentic, quality foods.”

Chris Lee, vice president of engineering at Great Dane, emphasizes, “Great Dane plays an important role in helping our customers ensure a safe food supply chain,

PREVENTIVE CONTROLS FOR ANIMAL FOOD

This regulation, which applies to domestic and imported animal food (including pet food, animal feed, and raw materials and ingredients), focuses on improving the safety of animal feed by preventing its contamination. Facilities producing animal food are required to have written plans that identify hazards, specify the steps that will be put in place to minimize or prevent those hazards, identify monitoring procedures and record monitoring results, and specify what actions will be taken to correct problems that arise. The rule also establishes certain current good manufacturing practices (CGMPs) that specifically address animal food.

The produce industry has a limited role in the production of animal feed; however, produce of insufficient quality routinely is culled from a harvest or process operation, and may be used for animal feed.

COMPLIANCE DATE: SEPT. 19, 2016

www.foodlogistics.com

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COVER STORY continued

and the safe and efficient delivery of food and other goods. We work with our customers to provide trailers and truck bodies that help them comply with food safety regulations, including the FSMA and its sanitary transportaFor food tion rule, which will apply processors, retailers to many of our customers. and restaurateurs, Great Dane continues to a single incident can introduce innovations to have a devastating help ensure the food supimpact on reputation ply chain remains safe.”

He adds, “Great Dane and revenue.” helps set the new standard Christopher Hoemeke, of clean in reefers. We Bureau Veritas North America responded to the FSMA by developing innovative products-such as our most recent introduction, Microban antimicrobial protection for our PunctureGuard and ThermoGuard liners-to help our customers comply and succeed. Great Dane’s Everest reefer is the only trailer on the market that offers this exclusive Microban antimicrobial technology, which actively fights the growth of bacteria that can cause odors and stains in the liner, and helps support FSMA requirements.”

Bud Rodowick, strategic relations for

❸

food safety and OEMs at Thermo King, explains: “Since inventing refrigerated transport nearly 80 years ago, Thermo King has a history with understanding the farmto-fork journey. The knowledge and insights gained over decades in the industry is what drives Thermo King’s innovations that play a role in improving food safety.”

He cites its Precedent platform as an example. “It delivers precise temperature control during transport, which is a critical component to ensuring food quality and safety.”

He adds, “Thermo King’s telematics solution, TracKing, gives fleets the ability to monitor cargo temperatures, and set and record refrigeration unit settings, which also plays a significant role in reducing spoilage, and satisfying tracking and reporting requirements of the FSMA rule on Sanitary Transportation of Human and Animal Food (STF).”

As for the FSMA’s impact on customers, Rodowick says, “The FSMA overwhelmed many who are trying to understand the relevance of the final rule and what it means for their business. Thermo King recognized early on that raising awareness and working to educate customers about the FSMA’s potential impact was critical.”

Thermo King has been meeting with fleets across the country for nearly two years to provide in-depth education on the 283-page rule. This training empowers carriers and arms them with questions to ask their shipping partners. “Carriers and shippers both need to understand the full regulation—not just pieces—and then have conversations with each other to make informed business decisions,” Rodowick says.

PRODUCE SAFETY

This regulation affects both international and domestic produce growers by establishing science-based standards focused on the growing, harvesting, packing and holding of produce on farms. Key requirements include agricultural water quality standards and testing, standards for using raw manure and compost, training, control of domestic and wild animals, equipment, tools, buildings, sanitation, as well as worker health and hygiene. This regulation is significant in that there now are enforceable regulations that articulate on-farm standards of conduct for the safe growing, harvesting, packing and holding of fresh produce.

COMPLIANCE DATE: JAN. 26, 2018

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Q: FROM YOUR PERSPECTIVE, WHAT IS THE LEVEL

OF PREPAREDNESS FOR THE VARIOUS ASPECTS OF THE FSMA, PARTICULARLY THE SANITARY TRANSPORTATION OF FOOD (STF) REGULATION, WHICH IS SET TO BECOME ENFORCEABLE ON APRIL 6?

A:

Penske Logistics’ Scollard says the company’s customers are very prepared for the STF regulation. “In both the past and present, we’ve followed good processes and procedures, so complying with this new regulation wasn’t difficult.

Most of our work with customers involves the transportation of food products to the store, so there are parts of the new regulation that did not strongly pertain to the dedicated contract carriage services we currently provide.”

Robertson of BOLT System says, “It’s important to remember that the STF regulation has two deadlines—one for large carriers with revenues in excess of $27.5 million and private fleets with more than 500 employees (which is April 6 of this year), and another for smaller fleets (which is April 6 of next year).”

He thinks most food carriers and private fleets were already well aware and prepared to meet the sanitary transportation regulations. “That’s because the FSMA also required shippers and warehouses to have food safety plans drawn up earlier this year, identifying the steps and procedures they will take to ensure the integrity of their manufacturing, processing and storage facilities. As part of those safety plans, they were also required to identify what steps will be taken to secure their transportation operations and provide them to their carriers.” www.foodlogistics.com

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FOOD FOR THOUGHT: INTEGRATING SAFETY COMPLIANCE IN FOOD AND BEVERAGE OPERATIONS

By Lee Hochberg

HIDDEN VALUE IN FOOD AND BEVERAGE OPERATIONS The food and beverage industry is a complex and dynamic sector, especially when it comes to operations that rely on liquid tank production.

This is when food safety and regulatory compliance is essential. When done effectively, liquid scheduling can ensure a high level of food safety in your processes and increase your competitive advantage.

Regulations concerning food safety can only get stricter as customer expectations of food quality increase. For food and beverage manufacturers, this can be an opportunity for growth by strengthening their food safety and delivering products that customers can fully trust.

But achieving effective production is easier said than done. Any food and beverage manufacturer producing liquids knows that tanks are not your ordinary piece of equipment. Your scheduling system must know this, too, and take into account all of your tanks’ complex characteristics, food safety activities and compliance checks.

KEEPING TANKS IN TOP CONDITION To get the most out of your liquid scheduling while maintaining food safety, it’s important to factor in the critical tank characteristics that impact productivity: Tanks need regular cleaning. Tanks require cleaning to prevent contamination and spoilage. The cleaning process depends on a host of complex requirements, which include sequence and characteristics of products, sanitization and clean-in-place (CIP) processes. CIP activities are mandated with strict rules to be adhered to. One example is that the CIP process in dairy tanks must be scheduled after every product change or 48 hours, whichever comes first. Additionally, you need to be able to recognize changeover values for these factors, as well as other characteristics, such as quality and brand.

Time-sensitive processes occur in tanks. Certain processes take time and the time is not entirely predictable. After the processes are complete, the product cannot be left in the tank for too long, as some products may spoil and have to be discarded. Others lose their properties, such as uniformity, and some rework or additional processing (e.g., stirring) may be required.

❹

Tanks have different properties. Planning tanks for use in food and beverage production can be a challenge. Multiple tanks are required in consecutive production stages and the use of liquids means the components are stored within the tanks themselves—as opposed to non-fluid materials, which can be stored elsewhere. The availability of tanks has to be taken into account when scheduling a production batch. The tank occupation requirement creates a high dependency between consecutive production stages: A disruption upstream or downstream can propagate through all production stages. You must be able to synchronize multiple process stages, and consider all variables and requirements of different batches to optimize the entire production process.

A tank’s batch may be destined for more than one packaging option.

In a make-to-stock environment with long lead times, bulk products often are produced before customers place their orders. In a make-to-order environment, you may want to combine different customer orders for the same bulk product, but with different pack configurations—all this while taking into account the product shelf life. To respond to changes in demand, the packaging plan must be able to match the existing product in tanks with a revised packaging plan.

Some tanks can only operate when full. Because of a tank’s specific properties or the need to prevent too much of an air gap at the top of the tank, partially full tanks are not always an option. To guarantee full tanks, you must ensure correct production volumes.

THE DIFFERENTIATING FACTOR Improving food safety is made easier with a scheduling system that ensures all key tank requirements are met. In an industry that’s becoming rapidly commoditized, manufacturers must identify a significant differentiating factor to set themselves apart and win customer loyalty— and absolute compliance with food safety regulations is the key.

Lee Hochberg is a senior adviser of integrated supply chain planning and optimization at Quintiq (www.quintiq.com), a provider of supply chain planning and optimization software. He has more than 35 years of experience in improving business performance in Australia, the United States and Europe.

FOREIGN SUPPLIER VERIFICATION

This regulation addresses import safety, and is closely tied to the preventive controls and produce safety requirements.

Importers are required to verify that food imported into the U.S. was produced to the same food safety standards that are required of U.S. producers. Food importers will be required to develop Foreign Supplier Verification Programs (FSVPs) that comply with U.S. standards, including the FDA’s proposed produce safety and preventive controls regulations.

COMPLIANCE DATE: MARCH 30, 2017

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← Penske Logistics reports its customers are very prepared for STF regulations as the company already followed many of the processes and procedures defined in the new regulations.

COVER STORY continued

However, “Smaller carriers and private fleets that have yet to discuss sanitary transportation compliance with their shippers might want to take a more proactive approach,” notes Robertson.

“We found that carriers and private fleets, both large and small, can be surprised to learn they may have to replace the refrigeration units on their trailers and van bodies sooner than expected. If their van bodies or trailers have separate compartments for refrigerated and frozen items, the refrigeration units on their trailers may not be able to monitor each compartment,” he says. “Accelerating their replacement schedule may be Most food unavoidable carriers and private as non-comfleets were pliance could already well result in the aware and loss of an prepared to entire shipmeet the STF long ment if an before the April 6 enforcement deadline.” officer takes Jerry Robertson, a reading in BOLT System the middle of the van or trailer, and finds a higher temperature than allowed. When replacing those refrigeration units, food distributors will want to be sure they can communicate with their fleet management systems.”

BOLT System advises food carriers meet with shippers and private fleets to establish procedures for capturing information on cargo conditions in transit. “Fleet managers should then examine their current equipment and dispatch software to make sure they can generate the required reports under the new federal rules,” says Robertson.

Sinclair of Seagull Scientific says, “While our product doesn’t enable STF compliance, we field questions daily about every aspect of the FSMA and there’s a great deal of confusion about what constitutes sanitary transportation. There are www.foodlogistics.com

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❺

THIRD-PARTY ACCREDITATION AND CERTIFICATION

This regulation aims to establish a comprehensive, credible and reliable program of oversight based on third-party audits and certification of foreign food facilities to help the FDA make decisions regarding the admissibility of imported foods.

COMPLIANCE DATE: TO FOLLOW ISSUANCE OF MODEL ACCREDITATION STANDARDS many variables to consider and the industry is looking for definitive answers for each circumstance, which are difficult to provide. Our larger, enterprise-level customers believe they are ready and have been in compliance for quite a while. Many of our smaller customers, though, lack the internal resources for regulatory interpretation and support, and they’re behind.”

Transfers loads from one pallet type to another

Great Dane’s Lee says the trailer manufacturer “works with customers to help them prepare, whether they are growers, processors, distributors or transporters. The various rules will add responsibilities for many in our industry and should strengthen the food safety system.

Our products help customers maintain the correct temperature of the products they ship.”

From his perspective, Thermo King’s Rodowick says, “a vast majority of shippers and carriers will not be prepared” for the enforcement stage of the STF regulation. “Many people are not aware of the breadth of the final rule and to the extent they are liable.”

He says that his discussions with fleets across the nation reveal that “it is evident that a significant number of shippers have not

Category 3 safety compliant Enhance safety for warehouse personnel Supports FSMA, HACCP and GMP compliance Help prevent contaminates from entering production areas Safer, cleaner & faster than other load transfer devices

developed and implemented the required written procedures determining appropriate transportation operations.

Without Many of our these smaller customers, written though, lack the procedures internal resources from the for regulatory shipper, carinterpretation and riers don’t support, have the and they’re information behind.” they need to make adElizabeth Sinclair, Seagull Scientific justments, if necessary, to their business.”

He adds, “We strongly encourage customers to proactively talk with their shipping partners. These conversations are critical for ensuring that the carrier fully understands what risks it is assuming when it signs a written agreement with its shipper,” says Rodowick.

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Q: ARE THE COSTS OF

COMPLIANCE WITH THE FSMA IN LINE WITH WHAT YOUR COMPANY AND YOUR CUSTOMERS ANTICIPATED?

A:

“Yes,” says Penske Logistics’ Scollard, adding, “We haven’t seen many of our customers asking for enhanced tools. We understand that it is the shippers’, or the food manufacturers’ and distributors,’ responsibility to put processes in place to protect the food. They certainly have the right to be very stringent in their requirements. A good example of this is when customers request real-time temperature updates for their products when they’re in transit—the frequency of updates

and record-keeping has not been a burden.”

McCloud Services’ Hottel also reports that costs have been in line with expectations.

From her perspective, Seagull Scientific’s Sinclair says, “For the track-and-trace portion of the law, there is a full spectrum of solutions with a full spectrum of price points.

“The FDA mandated automatic identification technology (barcodes or RFID) in recent medical device and pharma traceability regulation, but there’s no such provision in the FSMA. We’re seeing compa-

nies that are using highly manual processes, such as spreadsheet data entry, and we’re also seeing companies whose product tracing data is deeply integrated into their enterprise resource planning (ERP) systems. Some are even exchanging traceability data with trading partners, enabling a transparent and interoperable supply chain.”

According to Lee at Great Dane, “We have many large and small customers, and each has unique operations, so cost comparisons are not easy. We regularly work with our customers to help them customize a trailer or truck body with features that meet their needs, including the need to comply with regulations and keep costs within their budget. We offer superior total cost of ownership for our products, in part, because we work with our vendors to provide high-quality components that help ensure long-term value.”

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COVER STORY continued

Q: DOES YOUR COMPANY ACTIVELY

PROMOTE ITS ABILITY TO SUPPORT FOOD SAFETY? HOW IMPORTANT IS THIS TO YOUR CUSTOMERS? TO THE BROADER MARKETPLACE?

A:

“Penske Logistics is a process-driven company and built on supporting customer requirements,” says Scollard. “We like to promote the quality and cleanliness of our trucks, and we consider our adherence to food safety best practices to be market leading.”

McCloud Services’ Hottel says: “We promote our emphasis on food safety to our clients. Our employees are trained on the general aspects of food safety, in addition to the role pest management plays. We believe it is important for our employees, as contractors who service food plants, to know all potential routes of food contamination and prevention. This is Safety is always top of mind consistent with CGMPs.” According to Hottel, When you have the very best peoplein the cold chain as part of the company’s business, you keep them well guarded. continuing education, “all our employees attend We have daily pre-shift safety a McCloud-sponsored meetings, smart docks that Pest Invasion Food lock trucks in place until everyone is clear, protected Safety Seminar that is pick tunnels, and high open to the public and visibility blue light generates over 350 attechnology on our lifts. tendees. Top food safety professionals are present Learn more at at this all-day seminar, uscold.com or call us at: (856) 354-8181 which covers important and timely food safety topics related to pests, including the FSMA, public health and FDA regulations, foodborne illness and security. The

BEST IN COLD

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knowledge gained through our educational programs can help ensure compliance as contractors when we service food facilities. We can also assist clients with their food safety program development and implementation.”

Robertson says that BOLT System “just began to promote our capabilities to assist in meeting the requirements. We stress to customers how we built our fleet management system with many things that can help bring them into compliance.”

Yet “among our food distribution customers, we found that regulatory compliance is It is not their only important concern,” he for our says. “They well remememployees ber the negto know all ative public potential routes of perceptions food contamination resulting and prevention.” from the Patricia Hottel, McCloud Services 2012 E. coli contamination that struck Sunland, once the nation’s largest producer of organic peanut butter; the 2015 E. coli, salmonella and norovirus outbreaks at a leading Mexican restaurant chain; and the 2015 Listeria contamination at a leading ice cream producer. They know that poor sanitary transportation compliance can only contribute to food safety issues that can have devastating impacts on their business.” www.foodlogistics.com

4/3/17 11:39 AM

Robertson adds, “Our customers, particularly those who haul food, understand food safety will be crucial as the penalties for ignorance can not only come from the federal government, but also from consumers who can be far less forgiving.”

Seagull Scientific’s Sinclair notes, “There’s an increased consumer awareness around food safety, which gives companies another strong incentive to comply with the

❻

FSMA and other global regulations.

We’re currently developing several case studies with end users who see being a first mover in deploying state-of-the-art traceability technology as a differentiator in the marketplace and a powerful message about their commitment to the consumer.”

Hoemeke says, “Bureau Veritas supports FSMA requirements through our food safety and food

quality programs that certify farmto-fork or sea-to-plate product journeys. We provide our customers impartiality to data, allowing for trusted, ethical reporting to ensure they meet FSMA requirements.

We can also offer counsel on the correct setup of tracing product authenticity, further reducing any need for unnecessary expenditures due to mistakes. And, our equipment and technology can synthe-

SANITARY TRANSPORTATION

This regulation requires certain shippers, receivers and carriers who transport food that will be consumed or distributed in the United States to take steps to prevent the contamination of human and animal food during transportation. Specifically, the regulation will establish criteria for sanitary transportation practices for shippers, carriers and receivers regarding vehicles and transportation equipment, transportation operations, information exchange, training and recordkeeping.

COMPLIANCE DATE: APRIL 6, 2017

www.foodlogistics.com

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COVER STORY continued

size and analyze data to identify trends and opportunities for supply chain improvements, remedies and corrections,” he says.

“Simply put, consumer trust demands that the food we Penalties buy and feed ourselves comes from a safe, reputafor ignorance ble source. Until a unified can not only global tracking process come from is in place, food retailers the federal must ask hard questions government, about where their food comes from, how it was but also from processed, and how to consumers who can employ a traceable or verbe far less forgiving.” ified program to ensure its Jerry Robertson, quality.”

BOLT System Lee states, “Great Dane actively promotes our ability to support food safety, and we offer several trailer and truck body features to help our

customers take on the FSMA.” Rodowick remarks, “Thermo King is committed to delivering solutions that enable customers to maintain the highest food safety and quality standards possible.

Thermo King will continue to innovate and develop solutions that raise the standards for food safety and quality.”

What’s important to Thermo King’s customers, says Rodowick, “is that they are empowered with the knowledge to make informed decisions for their businesses.

Thermo King takes a proactive role in providing its customers with comprehensive education about the FSMA so that they have the information they need to facilitate important conversations with shippers.”

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The broader marketplace is equally concerned about food safety, adds Rodowick.

“Today, there is an even greater focus on maintaining the safety and integrity of food. Consumers are more knowledgeable about the foods they consume and are playing an important factor in driving demand for fresh, non-processed foods that require temperature control throughout transport. Everyone who touches the food chain in some capacity plays an important role in ensuring the safe transfer of food, which is essential for maintaining healthy communities.”

Q: HAVE THERE BEEN

ANY UNINTENDED CONSEQUENCES—FOR BETTER OR WORSE— THAT YOUR COMPANY ENCOUNTERED AS YOU WORKED TO COMPLY WITH THE FSMA?

A:

“The overall capabilities of technology in 2017 really improved food safety in the marketplace,” says Penske Logistics’ Scollard. “With better technology and increased competition, that helps make food safety technology better and more affordable.”

Seagull Scientific’s Sinclair remarks, “The lack of a standard syntax to carry traceability data has been a source of confusion. A common language between

The FSMA presents opportunities for responsive companies to differentiate themselves and

help their customers comply.”

Chris Lee, Great Dane

www.foodlogistics.com

4/3/17 11:39 AM

trading partners enables robust traceability. Without it, data exchange between nodes of the supply chain becomes almost impossible,” she says.

“GS1 piloted several studies, and the International Organization for Standardization (ISO) convened a work group sponsored largely by European Union food standards organizations and manufacturers to develop a standard for chain of custody in the food supply chain.”

Great Dane’s Lee comments, “As with any regulations, there are

❼

challenges and opportunities. Great Dane engineers design solutions that help our customers comply with the FSMA and other regulations. All of their efforts are focused on options that will help our customers ensure food safety and the efficient delivery of goods.”

He concludes, “The FSMA presents opportunities for responsive companies to differentiate themselves and help their customers comply with new rules. Great Dane is proud to introduce new products to help our customers comply with

FOOD DEFENSE

the new FSMA rules.

This is in keeping with our history of innovation and our purpose to ensure the safe and efficient delivery of goods.”

This regulation establishes requirements that most food facilities must follow for the purpose of preventing terrorist attacks on the U.S. food supply.

The final rule requires most FDA-registered food facilities to prepare and implement a food defense plan.

www.foodlogistics.com

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COMPLIANCE DATE: JULY 26, 2019

APRIL 2017

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SPECIAL REPORT

BY ROBERT A. NORTON, PH. D.

FOOD DEFENSE PLANNING — W

FOR WHAT PURPOSE?

Food defense is, in many ways, a young discipline, not because it hasn’t always been important for corporations (that occasionally experience product tampering, actual or threatened), but because the meaning and scope have been redefined and codified by regulatory requirements, with mixed results.

Large corporations are comfortable in their planning because they have the manpower needed to deal with both the scope of threats and requirements under the law.

Small and medium-sized businesses, on the other hand, struggle and will continue to struggle because compliance requires days and dollars beyond what they are already doing—not because they are not motivated to defend the integrity of their food products or because

they don’t intend to comply. More work laid upon an already full agenda sometimes leads to mistakes. Mistakes threaten the company image and damage profitability.

Defending Against Adversaries The United States Army Special Forces have a saying apropos to this discussion: “Slow is smooth ... smooth is fast.” What does that mean and what can food corporations learn from these elite warriors? The U.S. Special Operations Command is the military organization responsible for executing missions that conventional forces are not equipped or trained to handle. Without trivializing its mission, let’s transpose the idea of high-consequence mission realities

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E UR AT

CONTROLLED LT L L HT SO UTIONS EIG FR

RING TE LIVE MP DE ER

NORTON

hen I was young, I was always in a hurry. If I had a goal, I charged ahead, sometimes winning, but often failing because I didn’t have a fully developed plan and hadn’t thought about the next move. As an older, and hopefully wiser person, I learned goals are best assured when appropriate time (i.e., due diligence) is taken in the planning stage, before actual mission execution is considered.

Action without planning often leads to disaster.

At the same time, too much planning can impede. In other words, planning always has to be followed by action. We all know people who can talk a good game, but never actually get past the thinking stage.

A “no” decision—or one that is inordinately delayed—is, in fact, a decision not to act. In food defense, that choice could prove fatal to an actual customer or, on a larger scale, to the brand.

www.foodlogistics.com

3/31/17 2:57 PM

into the kinds of things that might be encountered by the food and agriculture industries.

Two observations emerge: Competition on a global scale is brutal for food and agriculture, and real adversaries are expanding in both numbers and capabilities. Food defense efforts must quickly become more robust. At the same time, global competition means budgets are tight and fiscal constraints are an ongoing reality.

Adversaries have fewer constraints.

In the realm of food defense, the defenders have to be right every time, while adversaries only need to overcome defenses once to achieve their goals. Adversaries want to act before defenses are robust and fully implemented, giving them an advantage. If corporations rush into defense efforts or fail to plan sufficiently, a lean budget may be squandered. Worse yet, the adversary wins. Wait too long, however, and the adversary again gains the advantage.

Utilizing Military Tactics Never forget: The ongoing reality is that the greatest threat for any food corporation is the insider. The resulting damage, whether caused by delay in planning or by impulsivity, impacts both corporate liability, and potentially, consumer safety.

How then can food corporations utilize Special Operations tactics?

In approaching this question, remember threats have both spatial and temporal elements.

In corporate security terms, this means adversaries can change both the character and level of threat very rapidly, depending on their own abilities and access, and also, in part, on how you react. Special Operations teams always seek to take the advantage away from adversaries, defeating them before they are able to act.

Fixed food defenses, like closed-circuit security camerwww.foodlogistics.com

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as, serve an important purpose, particularly at critical security points, such as product concentration points. They can be a liability, however, if they are depended on too completely or considered the only thing necessary to protect a business. No single food defense plan element is a panacea alone.

Threat actors, particularly insiders, seek knowledge of physical defenses, as well as knowledge of planning strengths and weaknesses.

A broken piece of technology is just that—broken—and therefore of no use in a pinch. An insider will know if your corporation is overly dependent on technology. Unlike human beings, technology can’t adapt, improvise and overcome. It’s all about the people; technology is only a supplement to a well-trained and flexible food systems defender seeking to defeat an adversary who is bent on destruction.

Suppose, for a moment, that a food defense plan is dependent on that aforementioned security camera. A thinking adversary might ensure the camera is not working, even for just a moment, at a certain time.

Remember—bad things may happen very quickly.

What happens if nobody is prepared and trained to respond?

That’s why key employees, like Special Forces operators, must train and work as a team, so they can detect and respond seamlessly in the event of an incident. Each member of a Special Forces team serves a specific purpose, but also cross-trains, enabling each to step in to take over a different role if a team member or supporting element is incapacitated.

Food corporations must take the same approach.

Like so many things in business or the military, most everything depends on the individual acting properly and in a timely manner.

For any food defense plan to be effective, rapid detection and response must be built in. Proactivity must always be a goal. Think here of the Special Forces team: Take the advantage away from the adversary. Detecting and neutralizing a threat before it has matured is always best. Redundancy and overlap must be included in planning and execution to ensure that vulnerabilities do not multiply should some key security element fail (which, as history proves, is bound to happen).

The same is true for personnel. If Joe is the food defense eyes in a particular area of a food processing plant, what happens when Joe isn’t at work? Good food defense plans overlap both defensive technologies and personnel.

For any food defense plan to be effective,

rapid detection and response must be built in.

Outside Threats Food and agriculture adversaries are not going away. Insider threats will persist, and external threat actors—like ISIS and other terrorist groups—will seek to use food and

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SPECIAL REPORT continued

water to achieve desired effects.

In response, food corporations— from the smallest mom-and-pop operations to the largest multinational corporations—must make food defense investments commensurate with the level and nature of the threats.

As part of this effort, food corporations also will need to invest in intelligence, meaning they will have to start looking for threats that are beginning to mature, whether internal or far afield. The tendency is typically to depend on the government and law enforcement to give the warnings, but increasingly, corporations realize they can’t necessarily depend on government warnings. Because the government’s intelligence responsibilities are so widespread and focused, developing threats to the food and agriculture sector might not be passed on to food and agriculture corporations soon enough to prevent food defense failures.

The Auburn University Food Defense Working Group is working to fill in some of those intelligence gaps that exist between corporations and government. In the coming year, the group will increase food-

and agriculture-related intelligence efforts. The best way to keep posted on developments is to visit the website: www.aufsi.auburn. edu/fooddefense/ or like the group on Facebook.

Food defense is what they do because, in the end, it is in everybody’s interest that our food system be kept safe.

Robert A. Norton, Ph.D., is a professor at Auburn University and chair of the Auburn University Food System Institute’s Food Defense Working Group. A longtime consultant to federal and state law enforcement agencies, the Department of Defense and the industry, he specializes in intelligence analysis, weapons of mass destruction defense and military-related national security issues. For more information or more detailed discussions about specific security-related needs, Norton can be reached at nortora@auburn.edu or by phone at (334) 844-7562.

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3/31/17 2:57 PM

SPECIAL REPORT

BY LARA L. SOWINSKI

PHYTOSANITARY AND

LOGISTICS COMMUNITIES CONVERGE ON FOOD SAFETY ISSUES Chapman University forum brings together interests from all sides.

I

n March, Food Logistics was invited to present at the seventh annual Chapman Phytosanitary Irradiation Forum, held at Chapman University in Orange, California.

The forum is organized in cooperation with the U.S. Department of Agriculture (USDA) with the goal of increasing understanding of the use of irradiation as a phytosanitary treatment to enhance global trade and prevent invasive pests.

Anuradha Prakash, forum organizer, and professor and program director of food science at Chapman University, and Jaymie Forrest, chief supply chain and commercial officer at ScanTech

DEBUNKING IRRADIATION MYTHS

Irradiation does not make foods radioactive, compromise nutritional quality, or noticeably change the taste, texture or appearance of food. In fact, any changes made by irradiation are so minimal that it is not easy to tell if a food has been irradiated.

Sciences Inc., as well as a presenter (and Food Logistics editorial advisory board member), are keen on raising awareness among USDA officials, phytosanitary experts and others in the academic community about the role logistics plays in supporting a safe food chain, and how cold chain best practices can contribute to extending the shelf life for fresh, perishable foods.

Study Demonstrates Viability of Irradiation In 2016, Prakash and three colleagues published the results of

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a study, “Effect of Phytosanitary Irradiation and Methyl Bromide Fumigation on the Physical, Sensory, and Microbiological Quality of Blueberries and Sweet Cherries,” which aimed to assess whether irradiation could serve as a suitable phytosanitary treatment alternative to methyl bromide (MB) fumigation for blueberries and sweet cherries, and also determine the effect of phytosanitary irradiation treatment on the survival of Salmonella spp. and Listeria monocytogenes on these fruit.

According to the study, “MB fumigation is a common phytosanitary treatment that meets most

countries’ export requirements.

However, it is a potent greenhouse gas and is scheduled to be phased out under the Montreal protocol.”

MB fumigation has other drawbacks. For instance, when fruit undergoes MB fumigation, it must be kept at a minimum temperature of 10 to 16 degrees Celsius for several hours. It takes another several hours for the gas to be exhausted after fumigation, “exposing the fruit to warm temperatures for an extended period,” the study states.

Moreover, “Little information is available on the effect of MB fumigation on blueberry quality or shelf life. However, on cherries, fumigation can increase bruising and pitting.”

In contrast, “irradiation treatment results in minimal temperature increase and fruit can be maintained cold if the facility is refrigerated,” the study notes.

Aside from assessing the impact of irradiation on shelf life, “growers are interested in knowing if the dose levels used for phytosanitary purposes also can enhance safety of berries. In general, berries are not common carriers of bacterial pathogens, but there have been incidents of foodborne illnesses linked to fresh berries.”

The study cites two examples: “In 2003, an outbreak of Salmonella enterica in California was linked to strawberries, resulting in 13 illnesses and two hospitalizations. In June 2009, there was a multistate outbreak of Salmonella Muenchen, which caused 14 illnesses and was linked to blueberries.”

While Listeria has not been associated with berries, the study notes that “recent outbreaks related to cantaloupes and apples suggest that contamination can occur in packing houses.” In addition, “while cherries are hydrocooled with chlorinated water, blueberries are not washed prior to packing, and neither fruit receives a lethal treatment to kill microorganisms. Thus, it would be beneficial if phytosanitary irradiawww.foodlogistics.com

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SPECIAL REPORT continued

FAQS ABOUT FOOD IRRADIATION How Is Food Irradiated?

What Is Food Irradiation?

Among the many areas regulated by the U.S. Food and Drug Administration (FDA), the agency also is responsible for regulating sources of radiation that are used to irradiate food. The FDA approves a source of radiation for use on foods only after it determines that irradiating the food is safe.

In its guide, “Food Irradiation: What You Need to Know,” the FDA provides answers to the following questions:

Food irradiation (the application of ionizing radiation to food) is a technology that improves the safety and extends the shelf life of foods by reducing or eliminating microorganisms and insects. Like pasteurizing milk, and canning fruits and vegetables, irradiation can make food safer for the consumer.

Why Irradiate Food?

Irradiation can serve many purposes, which include: • Prevention of foodborne illness. Irradiation can be used to effectively eliminate organisms that cause foodborne illness, such as salmonella and Escherichia coli (E. coli).

• Preservation. Irradiation can be used to destroy or inactivate organisms that cause spoilage and decomposition, and extend the shelf life of foods.

• Control of insects. Irradiation can be used to destroy insects in or on tropical fruits imported into the United States. Irradiation also decreases the need for other pest-control practices that may harm the fruit.

• Delay of sprouting and ripening. Irradiation can be used to inhibit sprouting (e.g., potatoes) and delay ripening of fruit to increase longevity.

• Sterilization. Irradiation can be used to sterilize foods, which can then be stored for years without refrigeration. Sterilized foods are useful in hospitals for patients with severely impaired immune systems, such as patients with AIDS or undergoing chemotherapy.

Foods that are sterilized by irradiation are exposed to substantially higher levels of treatment than those approved for general use.

tion treatment could also effectively reduce pathogen counts.”

Mold growth was one aspect measured by the study. It found that fumigated fruit showed earlier signs of mold growth compared to the control and irradiated fruit samples.

“MB can act as a fungicide,” acknowledges the study, “but at the treatment levels for phytosanitary purposes, it was not only insufficient to control mold, but seemed to

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There are three sources of radiation approved for use on foods: • Gamma rays, which are emitted from radioactive forms of the element cobalt (Cobalt 60) or cesium (Cesium 137). Gamma radiation is routinely used to sterilize medical, dental and household products, and also is used for the radiation treatment of cancer.

• X-rays, which are produced by reflecting a high-energy stream of electrons off a target substance (usually one of the heavy metals) into food. X-rays also are widely used in medicine and industry to produce images of internal structures.

• Electron beam, which is similar to X-rays and is a stream of high-energy electrons propelled from an electron accelerator into food.

Is Irradiated Food Safe to Eat? The FDA has evaluated the safety of irradiated food for more than 30 years and found the process to be safe. The World Health Organization (WHO), the Centers for Disease Control and Prevention (CDC) and the U.S. Department of Agriculture (USDA) also endorse the safety of irradiated food.

What Foods Are Approved for Irradiation?

The FDA approved a variety of foods for irradiation in the United States, including: • Molluscan shellfish • Beef and pork. (e.g., oysters, clams, • Crustaceans (e.g., lobster, mussels and scallops). shrimp and crab).

• Seeds for sprouting • Fresh fruits and vegetables. (e.g., alfalfa sprouts).

• Lettuce and spinach.

• Shell eggs.

• Poultry.

• Spices and seasonings.

How Do I Know if My Food Was Irradiated?

The FDA requires that irradiated foods bear the international symbol for irradiation. Look for the Radura symbol (shown at left), along with the statement “treated with radiation” or “treated by irradiation” on the food label.

Bulk foods, such as fruits and vegetables, are required to be individually labeled or to have a label next to the sale container. The FDA does not require that individual ingredients in multi-ingredient foods (e.g., spices) be labeled.

enhance mold growth, most likely as a result of the high temperature exposure.”

The study also evaluated damage to the fruit and firmness. In both cases, the irradiated blueberries and cherries fared better than those that were subjected to MB fumigation.

Ultimately, the study concluded, “Irradiated blueberries and cherries were not different than control fruit

for any quality attribute other than firmness, and irradiation did not improve or reduce shelf life.” And while MB fumigation did not impact quality attributes initially, “shelf life was compromised due to the development of sliminess and mold.”

Prakash and her colleagues added, “In our study, the fruit was allowed to warm up to 21.1 degrees Celsius, a process that took about 12 hours. Fumigation at that www.foodlogistics.com

4/3/17 11:23 AM

From left to right, Food Logistics editorial director Lara L. Sowinski joined Alberto Diaz, managing director of Spring Valley Fruits; Murray Lynch, CEO of Steritech; and Jaymie Forrest, chief supply chain and commercial officer of ScanTech Sciences Inc., on a logistics panel during the seventh annual Chapman Phytosanitary Irradiation Forum in March.

temperature took two hours and aeration required another four hours, resulting in an 18-hour break from the cold chain. In contrast, the irradiated fruit was exposed to ambient temperatures for approximately two hours. The extended exposure to higher temperatures for fumigation most likely is the cause of the greater damage, decay and shorter shelf life observed in the fumigated berries compared to the control.

“At 0.4 kilogray (kGy), the modest reduction in Salmonella and Listeria counts will not contribute significantly to improving safety.

Our results show that irradiation at a target dose of 0.4 kGy does not adversely or positively impact blueberry or sweet cherry quality or shelf life, and can serve as a good alternative to MB fumigation.”

In a recent call with Food Logistics, Prakash mentioned, “The fact that irradiation is a cold treatment makes it particularly suitable for fresh produce. The volumetric treatment helps with the irregular geometry of fruits and vegetables, and treatment can be done within the final package.”

Ensuring Food Safety in the Supply Chain My presentation to the forum attendees, entitled “Follow the Food: Opportunities for Phytosanitary Irradiation in the Global Food Supply Chain,” highlighted a handful of fundamental changes that are impacting the global food supply www.foodlogistics.com

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chain, which in turn, could present new opportunities for the application of phytosanitary irradiation.

While I am far from a phytosanitary expert, what I learned convinced me that phytosanitary irradiation technology is superior to MB fumigation—it’s more effective, more environmentally friendly and more expedient to apply/treat perishable foods, which prolongs shelf life and reduces food waste.

In short, the promising news is this: The United States is experiencing a steady rise in food imports and exports, with fresh fruits and vegetables among the top imports.

Ocean carriers are transporting large volumes of perishable foods via reefer containers through key gateway ports along the U.S. West, East and Gulf Coasts, while trucks likewise transport significant volumes between the U.S. and its

North American Free Trade Agreement (NAFTA) partners.

Meanwhile, niche ports like Port Hueneme in southern California and the Port of Philadelphia are handling more perishable food shipments, too, due in part to new service offerings from SeaLand and other ocean carriers.

At the same time, I think third-party logistics and cold storage providers that continue to look for value-added services to provide their customers would be wise to look into phytosanitary irradiation as one possibility.

Another trend—the increased production of and demand for locally grown food, as well as vertical and hydroponic farming—could also translate into future opportunities for phytosanitary irradiation.

Overall, there is real value in bringing food safety experts and logistics providers together to advance the conversation on how the two groups can work cohesively. A truly integrated global cold chain promotes efficiency and safety, as well as sustainHOW MANY freight claims ability and food do you file per month? security—and all of us play a role in achieving this If it’s more than 10, MyEZClaim goal.

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APRIL 2017 | FOOD LOGISTICS

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FOOD (AND MORE) FOR THOUGHT

BY SCOTT FABER

No Rules? No Food Safety E FABER

Editor’s Note: We appreciate the Environmental Working Group for its permission to republish this article, which was posted to its site on March 17, 2017.

42

veryone likes safe food. Polls show consumers want food safety to be a top priority for food companies and policymakers.

So it may be surprising to learn that some members of Congress are proposing to subject all new food safety rules to an unrelenting gauntlet of regulatory obstacles.

The House of Representatives already passed the Regulatory Accountability Act, which would require endless studies of potential agency alternatives, and subject new rules to layers upon layers of judicial review and congressional approval. Now the Senate is developing its own version.

It’s not just worker and environmental protection rules that would be blocked by these legislative efforts to—in the words of President Donald Trump’s chief strategist Steve Bannon—“deconstruct the administrative state.”

One of the likely victims of these new regulatory roadblocks would be new food safety rules.

Before any new food safety rule can be adopted, agencies such as the U.S. Food and Drug Administration (FDA) and U.S. Department of Agriculture (USDA) would first have to consider an endless array of regulatory options. Then the proposed rules would have to withstand two layers of review by judges newly charged to second-guess agency experts. Finally, any new rule would have to be approved by both the Senate and House.

In all likelihood, no food safety rule would ever emerge from this obstacle course. No wonder some experts started to dub the Regulatory Accountability Act the “filthy food bill.”

The filthy food bill is bad news for consumers because food safety

FOOD LOGISTICS | APRIL 2017

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rules save thousands of lives and prevent millions of illnesses.

Following the tragic deaths of four children who consumed E. coli bacteria, the USDA issued a rule to ban the sale of hamburgers contaminated with the pathogen.

Following the equally tragic deaths of nine consumers from salmonella in peanut products, Congress gave the FDA the power to develop food safety rules for food processing plants.

If the Regulatory Accountability Act or similar laws had already been enacted, it’s likely that none of these food safety rules would now be in effect.

Food safety rules aren’t just good for consumers; they’re also good for business. Food safety laws build the confidence of consumers and trading partners, and help food companies weed out bad actors. No

wonder the food industry strongly supports new food safety rules.

Despite the progress that’s been made, unsafe food continues to kill 3,000 Americans every year and send 128,000 to hospitals. Putting endless regulatory roadblocks before the FDA, USDA and other public health agencies doesn’t make them great. It makes our food less safe.

Scott Faber leads a team that works to improve food and farm legislation, chemicals policy, and a host of other issues important to the Environmental Working Group (EWG) and its supporters. Prior to joining the EWG, Faber was vice president of federal affairs for the Grocery Manufacturers Association, where he spearheaded efforts to enact the Food Safety Modernization Act, which sets new food safety standards for food manufacturers and farmers.

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