With COVID-19 seemingly further behind us with each passing day, many aspects of our personal and professional lives are beginning, once again, to change. But this time in a more welcome direction. Indeed, we are now beginning to see less COVID-19 mandates, less COVID-19 masks, and less COVID-19 illnesses and hospitalizations. But as the pressures exerted by the challenge of COVID-19 upon our professional lives continues to ease, there are now new frightening pressures exerted by other powerful forces ready to pounce and take their place.

When COVID-19 was roaring across America, the federal food safety inspection agencies (FDA and USDA) changed many of their inspection priorities. On the FDA side, the agency for all practical purposes stopped visiting food facilities and conducting routine inspections.

Now, after nearly two years of hibernation, the agency is awakening and coming out of its proverbial cave. As the mammoth multi-billion dollar agency squints from the bright sun, and stretches its legs, arms and claws, we hear it letting out a mighty roar that can be felt across the nation. From an inspection standpoint, the bear is on the hunt. And, as this powerful creature begins fanning out in its search of its next food facility prey, the bear is very, very hungry.

Indeed, the FDA inspections we have been watching unfold over the course of the last six months have been quite intense, in many cases lasting three to four weeks instead of three to four days. The paradigm appears to have shifted as well, moving from “we educate before we regulate,” to we regulate “in order to educate enforce.” And, like a hungry animal which becomes excited from the smell of blood, when the agency sees something objectionable, it increases the agency's hunger and the inspection intensifies. In some cases, this cycle continues for so long that, when the agency does finally leave, the company feels as if it’s been left in tatters.

So, how do you avoid feeding the bears? First, don’t give the bears an opportunity to feed. In my opinion, inspections are different now than they were two or three years ago. It is almost as if FDA (and, their state counterparts) are reinventing the inspection process, while at the same time conducting swab-a-thons, spending countless hours observing sanitation and production, and looking tirelessly for violations. In some cases the agencies are finding them because, while the bear was in hibernation, some organizations became more complacent.

Now that the bear is actively back on the hunt, now is the time to check your programs, make sure they are being tightly followed, that your employees are adequately trained, that you are devoting enough time to sanitation and quality control, and that your operations and programs will be the best they can be when the bear finally arrives. You might also consider putting your FDA hat on for a day and conduct your own swab-a-thon. This way, if there is anything in the environment which might send the agency into a wild frenzy (like a resident strain of Listeria), you can get rid of it before the agency arrives. The same can be said for USDA, which is increasingly coordinating with FDA in dual-jurisdiction facilities and conducting its own swab-a-those during Food Safety Assessments as well.

On this Monday morning, close your eyes, just for a moment. Somewhere on the horizon, just beyond the four walls of your facility, you might hear a roar. Just like when dealing with a real bear, make sure that there is nothing left in your operations or programs for the bear to stop and feed on. If you do a good job now, the bear will move along quickly and focus, instead, on its next set of prey.

Don’t feed the bears

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