In this unprecedented time of worldwide shutdowns and from-home working, food industry personnel continue to journey daily to their fields, production plants, and retail and restaurant establishments to harvest, produce, stock, prepare, and distribute food. Although those daily operations have changed and complexities have increased with the pandemic, the need for food safety and quality has not, in any way, diminished.
One key area of food safety on which we need to focus to ensure business continuity regardless of, and considering, the current societal environment is that of recall and crisis management. Issues leading to recalls can occur throughout your supply chain, in the plant, or after product is out your door. Let’s take these one by one, focusing on both regular business and the impacts of the current environment:
Your supply chain. The FSMA requirements for the implementation, and continued management, of a risk-based supply-chain program has become increasingly complex but even more critical as businesses deal with supply originating from COVID-19 crisis areas, closed or vastly limited foodservice establishments, and increased consumer demand for basic “stock-up” foods. While having to reassess the risk of your suppliers, and likely bring on new suppliers, you are likely also having to re-evaluate the balance of foods you are producing to weigh more heavily toward consumer products. Included in that risk could be suppliers of newly in-demand foods who may be cutting corners to get product out; and included in the balance determination is the risk of demand reduction once consumers’ pantries and freezers are stock. It’s a new world with continuing food safety issues.
In the plant. While FDA will not be making routine on-site visits, they will continue monitoring food safety and will follow up with investigations on an issue-driven basis. Additionally, routine sanitation and environmental monitoring and control practices are of even greater concern than ever. Not only are they critical for keeping your employees safe, but a recall which is expensive, time-consuming, and brand-impacting at any time, would be even more so now. And with social media currently the primary means of communication for so many around the world, a customer complaint posted on Facebook, Instagram, or Twitter would go viral even faster – particularly if it were to impact the more vulnerable of the population, such as the complaint a processor received about small glass fragments in a jar of their baby food. Managing such a crisis and recall not only requires recall action and consumer communication, but also a great deal of regulatory interaction that is not in the normal day-to-day realm (or even today’s abnormal realm).
Post-production. Increased home delivery and consumer stockpiling are putting a heavier emphasis on product shelf-life and distribution temperature controls. If you’ve not done so before, it would be a good time to conduct a risk assessment of your distributors’, and even retailers’ practices.
A new way of doing business. TAG understands that it is much easier to define the issues and the “shoulds” around them and the increased difficulties of assessing and managing risk when you are unable to visit suppliers or distributors and even have limits within your own plant. It is for just those reasons that TAG is not only continuing to provide its expertise and guidance in mitigating operational, regulatory, and reputational risk in food facilities, we are amping up our capabilities to increase our virtual technologies for individual client support. As a company that was founded as a virtual, work-from-home business, with TAG experts located across North America, we’ve been a step ahead since the beginning of COVID-19. As such, we have long had virtual training programs for clients, and we are now translating our in-person facility visits to virtual options, such as the remote visual technology we are adapting.
TAG remains your key source for driving food safety best practices to mitigate risk and protect your brand, and – just as you all have had to adapt to a new way of doing business, so, too, have we, and it is a new way that will make us an even more versatile, nimble, and customizable in the long run. We look forward to helping you and your team through this difficult time, and onward.
For more on TAG’s Business Continuity, see the Message from the CEO.)
About The Acheson Group (TAG)
Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG’s team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. www.AchesonGroup.com