As we review the most recent recommendations in the Food Safety Modernization Act (FSMA), we learn that the rules are expanding from a HACCP focus on preventing post-process contamination to a FSMA food safety plan that takes a more preventive approach by identifying potential risks and implementing appropriate controls to proactively prevent contamination. Additionally, this Plan (also referred to as Hazard Analysis and Risk-Based Preventive Controls or HARPC) applies to each individual facility and must be created and overseen by a preventive controls-qualified individual (PCQI) as defined by FSMA.
While the United States ranks among the most globally trusted by consumers for safety of food purchased and consumed, there are constant reminders in the news of recalls relating to cross-contamination, food allergens and labeling issues.
To better understand why food safety regulations are expanding to include steps designed to prevent contamination in the first place, it is important to understand how consumers perceive the food business and food safety, particularly at the retail level. While the United States ranks among the most globally trusted by consumers for safety of food purchased and consumed, there are constant reminders in the news of recalls relating to cross-contamination, food allergens and labeling issues. Making matters worse, there have been several cases of extreme negligence, including the recent Peanut Corporation of America case where the owner knowingly refused to cancel contaminated peanut butter orders resulting in nine deaths. The company is no longer in business and the owner is serving 28 years in prison!
Ready-To-Eat foods … are inherently presumed to be safe to eat by consumers.
Ready-To-Eat (RTE) foods (a fast-growing sales category) purchased at a grocery store, restaurant or from a street vendor that are considered edible without further processing are inherently presumed to be safe to eat by consumers. Furthermore, strict food sanitation laws infer that the “obligation of prevention” is automatically assigned to the food provider. This means that if a food handler produces a product that is understood to receive no further treatment to prevent hazards of any type, the consumer will believe the product is safe to eat—an obligation for any processor to take seriously!
What defense do processors have against cross-contamination and liability? The onus is on food processors to protect their products at all levels, starting in the manufacturing environment. Demands by consumers for foods that are healthy and safe for consumption continue to drive current market trends. The incorporation of preventive controls as required by the Food Safety Modernization Act, is a key component in a food safety program that helps prevent the adulteration of RTE foods.
There are additional consumer perspectives that drive government regulation of food safety, including their skepticism about food production. The consolidation, integration and application of technology that makes food safer, more available and more affordable than ever before also prompts concerns. Consumers wonder if technology benefits society or only those who control it. Skepticism abounds on the motivation of those in food and agriculture. They increasingly believe that because farms and food companies have dramatically increased in size and are using technology they don’t recognize or understand, the food system is likely to place profit ahead of public interest. No amount of science-based information is going to change that perception unless consumers trust the fact that despite the changes in size, scale and technology, the food system will do the right thing for consumers.
But just as the techniques of food production and processing have progressed tremendously, consumer attitudes about food have also changed. Technology and innovation have made food safer, more affordable and more available than ever before. At the same time, consolidation, integration and technological advances in the way food is produced have increasingly resulted in the food system’s being viewed as an institution not to be trusted.
The research found two factors are critical to igniting outrage: First, if the issue is a “concern” to the public, and second, if it has an “impact” on those perceived as vulnerable.
The Center for Food Integrity (CFI) identified specific factors that cause consumers to exhibit social outrage. The research found two factors are critical to igniting outrage: First, if the issue is a “concern” to the public, and second, if it has an “impact” on those perceived as vulnerable. Specifically, issues that can have an impact on “me and my family” heighten these factors. That’s why food safety and the impact of diet on health top the list of issues on the edge of outrage, waiting for a triggering event to push them over the brink. And that is why in the wake of deadly foodborne illnesses, the U.S. Food and Drug Administration enacted the Food Safety Modernization Act (FSMA). It is the most sweeping reform of food safety laws in the U.S. in more than 70 years and is designed to shift the food safety focus from responding to contamination to preventing it.
In another nationwide consumer survey conducted by CFI in 2007, consumers were asked to rate their level of confidence, perceived competence and trust in various groups of influencers in the food system based on questions related to food safety, environmental protection, nutrition, animal well-being and worker care. On every issue, confidence, or shared values, was three to five times more important than competence for consumers in determining whom they will trust. These results are a call to action for the food industry.
It is clear now that status quo arguments made about food safety have very little to do with relevant science or safety and everything to do with ‘trust.’ Given that industry, in general, is demonstrably mistrusted in things like social media and the fact that scientists are ill equipped to engage a Twitter argument, it is entirely possible to win a regulatory battle and lose the war! No longer is it sufficient to rely solely on science or to attack our accusers as a means of protecting self-interest. This new consumer-based environment requires new ways of engaging and new methods of communicating if we want to build trust, earn and maintain social license and protect our freedom to operate.
