Wednesday at the Food Safety Summit began with a keynote on the future of food safety culture. The presentation featured a panel of representatives from industry, the U.S. Food and Drug Administration (FDA), and the U.S. Department of Justice (DOJ) who discussed their perspectives on the future, implementation, and importance of food safety culture. The panel was moderated by Shawn Stevens, Founder and National Food Industry Lawyer at Food Industry Counsel LLC. Panelists included Conrad Choinere, Ph.D., Director of the Office of Analytics and Outreach at FDA’s Center for Food Safety and Applied Nutrition (CFSAN); Matthew Lash, Esq., Assistant Director of DOJ’s Consumer Protection Branch; Donald Prater, D.V.M., Associate Commissioner for Imported Food Safety at FDA’s Office of Food Policy and Response; and Michael Roberson, M.S., C.F.S., C.P.-F.S., Director of Corporate Quality Assurance for Publix Supermarkets Inc.
Stacy Atchison, Publisher of Food Safety Magazine, kicked off the keynote presentation with warm welcomes and a message of gratitude. “It is exciting to come together again [in person], but that excitement is underscored by the weight of all that has occurred [during the COVID-19 pandemic],” she said. “Many of you were tasked with guiding your companies through uncharted territory to protect your fellow employees and keep safe food on the tables of families in your communities and around the world. So, thank you.”
Food Safety Magazine Presents its 2022 Distinguished Service Award
Ms. Atchison then invited Adrienne Blume, Editorial Director of Food Safety Magazine, to join her in honoring Joe Stout, R.S. with the magazine’s 2022 Distinguished Service Award. “Food Safety Magazine presents its Distinguished Service Award to honor individuals that best exemplify the characteristics of the dedicated food safety professional,” Ms. Blume said, before calling Mr. Stout to the stage. “Nominees are also those who have worked tirelessly behind the scenes, profoundly impacting food safety around them.”
In addition to thanking Food Safety Magazine for the award, Mr. Stout also thanked sanitation workers everywhere. “I accept this award in solidarity with the sanitation community,” he said, and then continued with a request. “I have an ask for you when you go back to your facilities, and that is to take some time to recognize your sanitation workers for their hard, and often thankless, work.”
Chip Manuel, Ph.D., Food Safety Science Advisor at Gojo Industries, owner of Purell and the sponsor of the keynote, opened the floor to the panel. Following Dr. Manuel’s introduction, Mr. Stevens began the panel discussion by remarking on the exciting future of food safety as the emphasis on culture grows. “[Food safety culture], I think, will have a larger impact on the safety of our food than anything I’ve seen in the last twenty years,” he said. Mr. Stevens continued by discussing his work as a food defense lawyer and how he has seen food safety improve during his time in the industry. “With a good food safety culture, everything else gets better,” he said. “All of our decision-making will be driven by this goal of a robust food safety culture.”
Food Safety Culture According to FDA
Mr. Prater and Dr. Choinere, representing FDA, were the first panelists to take the podium. They started by deliberating the question: “What is food safety culture?” According to Dr. Choinere, “Food safety culture is not just behaviors, it is also the values, the perceptions, the beliefs, and the attitudes within an organization that actually result in those behaviors.” He stressed the importance of operationalizing food safety values in a way that results in safe, hygienic behaviors. Dr. Choinere expressed that values translating into behaviors does not happen on accident; it requires commitment on behalf of organizational leaders and the development of a system. Dr. Choinere acknowledged that every organization will have its own approach to food safety culture, and that FDA is a resource to assist industry in developing food safety culture, rather than define food safety culture for industry.
Mr. Prater related food safety culture to FDA’s New Era of Smarter Food Safety, of which food safety culture is one of the four core pillars. Mr. Prater stated that food safety culture intersects with everything FDA does under the New Era of Smarter Food Safety. He outlined FDA’s goals for food safety culture, which are: to promote food safety culture throughout the entire food system, to promote food safety culture throughout FDA, and to develop and promote smarter food safety consumer education campaigns.
Mr. Prater also discussed how food safety culture has emerged as a legitimate discipline within food science in the last decade, and how FDA is using research on food safety culture. He revealed that FDA is working on a systematic literature review—to reference internally, and perhaps share with industry partners—that identifies the challenges, barriers, and opportunities for food safety culture. FDA has also developed an internal resource library on the topic. Mr. Prater expressed FDA’s hope that research on food safety culture will help FDA determine the answers to questions such as, “What is food safety culture? How does it impact public health? What can we measure? And how can we take it all into account?”
Dr. Choinere spoke on what FDA has been doing to assess and strengthen its internal food safety culture, such as holding discussions on the topic at all levels of the organization, identifying what the goals are for food safety culture, and ensuring alignment in the agency’s approach to promoting food safety culture throughout the food chain. “Food safety culture is hard work and an ongoing process,” he said. “You have to continue to foster it.” Dr. Choinere also revealed that FDA has developed internal food safety culture training, which explores the key elements of a positive food safety culture.
“FDA is not the leader of food safety culture. The real leaders are industry,” Dr. Choinere continued. “How can FDA help propel that effort [to develop food safety culture] in industry?” One way FDA is trying to propel food safety culture is by establishing positive food safety social norms for facilities to adopt. To achieve this, FDA is collaborating with organizations that have exemplary food safety culture to learn about their approach and share information throughout the industry.
Food Safety Culture According to Industry
Mr. Roberson spoke from the industry point of view on food safety culture and the impact it has had at Publix, which has been recognized for its excellence in food safety throughout the past decade. He began by discussing the importance of prioritizing food safety at all of a company’s levels, including the top. “Most companies have a department that is tasked with leading food safety throughout the business, but few prioritize food safety as a strategic imperative,” he said. “It is vital to have food safety as a business objective that can be easily understood and cascaded throughout the business.” Mr. Roberson further explained that focusing everyone within an organization on food safety allows for extensive measurement of food safety objectives and a better awareness of where improvements may be necessary.
Mr. Roberson provided several examples of how Publix ensures operational excellence throughout the company. Specifically, Publix requires relevant certifications for its staff and provides internal trainings on regulatory standards, as well as makes use of monthly and weekly educational materials that lead to greater conformance in food safety practices. These materials include infographics, videos, tips, and others. Publix fosters food safety cultural awareness by monetarily incentivizing learning in the area, as well. Mr. Roberson also mentioned that Publix partners with universities across the southeastern U.S. to provide free trainings to small- and medium-sized companies.
Mr. Roberson also stressed the importance of evaluating the performance of food safety programs. “It is vital that we have objectives that are clearly understood and can be cascaded throughout the organization,” he said. To do this, Publix uses “food safety score cards,” which are reviewed by a food safety advocate team on a monthly basis. A cross-functional food safety compliance team also reviews Publix’s food safety metrics on a quarterly basis. An analysis of key metrics is then reviewed by Publix’s executive leadership team and presented to the board of directors.
Mr. Roberson also encouraged engagement with regulatory bodies and professional associations to drive continuous improvement in food safety. “We can help lead and drive those improvements with others who are committed to raising the bar,” he said.
Mr. Roberson explained the importance of having plans in place to deal with issues when they arise. “It is vital that businesses have a strong business continuity program that helps them face recalls,” he said. Mr. Roberson added that there are issues other than recalls that need to be anticipated, such as supply chain challenges and natural disasters. He also shared that it is important to communicate business continuity plans with relevant state or federal officials. “FDA knows how we are going to handle [these events] because the plans have already been shared and the relationships have been established,” he said.
Food Safety Culture According to DOJ
When food companies have food safety incidents that affect public health, DOJ gets involved. DOJ identifies and prosecutes the most serious unlawful conduct in order to protect consumers, uphold the integrity of the regulatory process, and prevent future violations of federal laws and regulations. According to Mr. Lash, food safety culture is a factor that DOJ takes into account when making enforcement decisions. DOJ also works closely with FDA when making such decisions.
Important food safety culture considerations that DOJ takes into account when making enforcement decisions include the compliance programs an organization has in place, what remedial actions an organization may or may not have taken, and the speed and scope of an organization’s response to a foodborne illness outbreak. Mr. Lash highlighted an organization’s internal communications as crucial evidence that can help DOJ determine whether an outbreak happened because of negligent food safety culture, or despite a positive food safety culture. The existence and quality of a culpable organization’s food safety culture can be the determining factor in whether DOJ decides to pursue criminal prosecution, enter a civil consent decree, or decline prosecution altogether.
Mr. Lash acknowledged that “incidents can happen despite a company and its employees’ best efforts.” He continued, “Building a culture of food safety matters for safe food, and it matters to enforcement.”
Question and Answer
The keynote panel discussion ended with a Q&A session. One attendee pointed out that some food production companies are more hesitant to cooperate with FDA than others, and asked Mr. Stevens if this could be partially due to influence from outside legal advisors or consultants. Mr. Stevens answered, “You are absolutely right. Outside advisors can have poor views on food safety culture too, or companies might hire lawyers who know nothing about food safety.” He continued, “However, I have been seeing a shift to more positive food safety culture and cooperation over the last ten years. We are all beginning to talk to one another; that is the way we win.”
Mr. Stevens then directed a question at Mr. Roberson about strategies to encourage industry to be more risk-aware so that companies are motivated to foster positive food safety cultures. Mr. Roberson answered by acknowledging that every company has its own culture, and provided an example for how companies can encourage one another to cultivate positive food safety culture. “When there is a food safety incident,” Mr. Roberson said, “I want to know who the suppliers are. We want to know when there is an opportunity … to connect with the supplier, [and] to understand what they are doing to correct the event before we bring their product back online.”
A second attendee asked Mr. Lash about how long food safety culture has been part of DOJ’s thought process. Mr. Lash responded, “[DOJ has] always been well aware of the fact that companies can do the right things but still have food safety incidents.” He continued to explain that naming good food safety behaviors and attitudes as “culture” is the only new element of DOJ’s thought process. Regarding DOJ’s consideration of food safety culture, Mr. Lash acknowledged that there may be a disconnect between DOJ and industry because prosecutions that are not perused due to a company’s positive food safety culture are not publicized.
Mr. Stevens concluded the keynote by saying, “It is important for us food safety professionals ... to try to do a better job of communicating [between industry, regulatory bodies, and consumers]. I think that is when we will start to see a distinct change.”
The 2022 Food Safety Summit is taking place in person at the Donald E. Stephens Convention Center in Rosemont, Illinois from May 9–12. Stay tuned for more conference coverage!