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2022: Hold on to Your Hat: Squalls Ahead

As we discussed in last week’s Insights article, 2021 was a highly challenging year on all fronts for the food industry … and with the COVID-19 Omicron variant on a rampage, we are definitely not out of the woods. At least in the first quarter, the industry will continue to be hit with absenteeism, temporary workers, supply chain disruptions, and general production challenges; and throughout the year we see both FDA and FSIS having some very focused regulatory agendas and industry expectations.

To weather the challenges while meeting regulatory expectations, we foresee more and more entities looking at the 2022 manifestation of food safety culture in their facilities. Businesses are seeking to determine if employees are seeing food safety as a collective issue. Are they taking ownership or seeing it as “someone else’s problem” to deal with? Ensuring a culture of food safety has been growing in focus, and it will become even more important as we deal with the outside pressures of 2022.

On the regulatory horizon, we see FSIS continuing its focus on Salmonella in poultry and FDA continuing to navigate the depths of traceability.

FSIS. The leaders of FSIS have made a commitment to reducing Salmonella in poultry. It’s not the first time such a commitment has been made, as prior administrations have attempted to tackle the issue as well, but there has been little progress made. While Listeria and E. coli issues have been somewhat reduced, Salmonella has refused to drop. So the agency is again taking the helm to lead the industry into a reduction through regulation.

Salmonella in poultry is, in fact, likely to become a huge focus in 2022, though we’re not sure of the direction the regulators will take. They may declare specific serotypes to be adulterants; they may look for enumeration; or they may focus more on the lifecycle. Whichever course they take, you can expect it to follow a resolute and steadfast track toward measurable reduction.

FDA. It should come as no surprise that we see traceability – that has lurked for so long on the horizon – coming to the forefront in 2022.  FDA has been talking about its New Era of Smarter Food Safety, and we see that talk turning to action this year, with new traceability requirements being finalized.  Helping to enable progressive traceability is FDA’s leveraging of molecular technology, e.g., whole genome sequencing (WGS), which we don’t see slowing down at all. Each day the database grows larger and stronger, increasing the likelihood that something could track back to your facility.

And when an issue is connected to you … FDA is expecting the industry to move very swiftly. There will be very little slack in FDA informing you of a situation in which your product was implicated, stating that they are issuing a press release tonight, and asking what you are going to do about the problem.

With all this, whether you are a food or beverage facility under the answerable to FSIS or FDA, our top recommendation for 2022 is: Be Prepared.

The storms will continue in 2022; the headwinds will blow, the turbulence carrying riptides and undertows. All brought challenges in 2021, which the food industry navigated extremely well, but I don’t see things slowing down or abating any time soon. So, the best you can do is stay informed and keep food safety and employee welfare as top priorities, and be prepared: We will come out on the other side of the storm, but at least a few squalls still lie ahead.

For more on TAG’s expectations for 2022, view the latest TAG Talks video: How Will the Challenges of 2021 Trend in 2022?  If you need assistance weathering any of the storms or squalls, give TAG a call. We can help.


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