There is, unfortunately, tremendous risk associated with the production and distribution of food ingredients and finished products. Even the best and most successful companies can find themselves on the wrong side of an emerging recall, outbreak, or intense governmental investigation. Notably, when problems do occur, they are often triggered by certain discrete and avoidable events or failures which we routinely see recurring within the industry.

The first of these, which I wrote about in my last blog, is a company’s failure to invest in qualified and credentialled food safety leadership. If the food safety leaders within a company do not have the appropriate skills or experience, failure will be more likely to occur. Thus, the singular most important thing a food company can do to protect itself is to invest in, and then support, its food safety management.

In turn, appropriately skilled and experienced food safety managers will insist on the development, implementation, and proper execution of a robust environmental monitoring program for pathogens. Notably, the majority of food product recalls which are announced for the presence of pathogens now involve large amounts of product manufactured over multiple days, weeks, months, and sometimes years of production. What this means is that many companies routinely find themselves battling with persistent strains while, at the same time, failing to completely and appropriately eliminate them.

This brings us to our third failure – the lack of an appropriate response to positive findings in the environment. Far too often, a food company will identify a trend of positive environmental findings, and not take appropriate action to eliminate the hazard. While most companies will aggressively clean, sanitize, and retest an area testing positive, most fail to initiate, conduct, or appropriately execute a true “root source” investigation. When these trends are allowed to persist, history has taught is that these pathogens will eventually make their way into the food products.

The fourth area where food companies routinely make mistakes is the failure to respond appropriately to an FDA 483 or USDA Notice of Intended Enforcement (NOIE), which are sometimes issued following the conclusion of an inspection or comprehensive food safety assessment. When a 483 or NOIE is issued by the agency, the response must be well documented and well supported with evidence demonstrating the completion of any corrective actions. In the absence of an appropriate response with appropriate support, FDA or USDA could initiate additional enhanced regulatory action, which could threaten to shutter the company.

The final food safety failure many companies can and often make is the failure to procure appropriate recall insurance. When a company relies upon an unqualified food safety leader, doesn’t have a robust environmental monitoring program, and/or does not respond adequately to environmental positives (by finding the root source), either FDA or USDA will likely find the problem for them during the next inspection. When they do, they might also determine that a recall is, in fact, warranted.

The best way to protect against the high costs associated with a large-scale recall is to buy recall insurance. Whether triggered by a governmental inspection, a positive finding of pathogens in a finished product at retail, or a cluster of alleged consumer illnesses, recalls can be extremely expensive. Thus, having an appropriate level of insurance could make the difference between a company continuing to exist or having to shutter its doors.

Notably, however, if a food company invests in strong food safety leadership, supports that leadership, adopts robust environmental monitoring programs, and responds appropriately and aggressively to environmental positives, the likelihood of ever being associated with an outbreak, having a recall, or needing recall insurance will be reduced substantially.

Thus, while wishful thinking is never a good strategy, making those decisions that will enhance food safety, and secure the long-term the survival of the company, definitely is.

The 5 food safety failures that can ruin your company

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