Even though the pending reform bills focus on manufacturing and holding facilities, Brackett notes that companies in the foodservice and retail sectors can also benefit from putting their own protocols for food safety on paper. In Nov. 2009, FDA released the 2009 Food Code, which serves as a science-based best practices guide for these sectors, as well as a regulatory model for states. The guide includes information on how to set up a voluntary HACCP program for retail food operations and other risk-based food-safety management techniques. “As a result of the push for reform,” he says, “many states are putting increased emphasis on improved food-safety practices, and they may become more aggressive about adopting and/or going beyond the FDA Food Code guidelines.”
Final legislation is also likely to include more emphasis on traceability, which will have an impact on all segments of the supply chain. “Traceability is an important component of any new legislation, because it allows us to shorten and more quickly respond to, and resolve, any kind of food-contamination event,” says Brackett. “A coordinated system not only helps us trace back to identify the source of an issue, but also to trace forward to identify any products that might also become contaminated that we wouldn’t otherwise know about.” He suggests that companies evaluate their recordkeeping systems in advance of new laws with a view toward supplying more traceability information to regulators.
Another proactive preparation step is to make sure that your operation has a good supply-chain food-safety management system in place. “One of the real drivers of change is going to be the large food companies and foodservice operators demanding that all of their suppliers have strong process controls and HACCP plans in place,” says Shawn Stevens, food industry attorney, Gass Weber Mullins LLC, Milwaukee. “If I am Nestlé or Wal-Mart, I am going to demand that my suppliers have extremely robust systems, and I am going to verify that they do—FDA inspections or new legislation aside. Companies that want to do business with the big industry players will be financially motivated to improve their systems.”
Hall agrees that, to a certain extent, the message is that food companies must continue to police themselves by making sure their own, and their suppliers’, systems are in compliance with food-safety laws and standards. “Food-safety reform starts with each company involved in the production, handling or sale of food making sure their own systems are effective. If each link in the food supply chain is individually strong, the whole system is stronger.”
Julie Larson Bricher is president of Quiddity Communications, Inc., an Oregon-based food safety editorial services and communications company. She also is communications director for the National Center for Food Safety and Technology, Illinois Institute of Technology. Larson Bricher can be reachedat jbricher@iit.edu.
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