Marler at Marler Clark says the PCA outbreak underscores the necessity on the part of private label manufacturers and re-manufacturers not to rely on indemnity agreements or insurance policies between themselves and the producer. “They need to get more engaged. When a company like Kellogg is relying on a company like PCA, Kellogg is taking the bigger risk because of its brand. So they need to do more than what they are currently doing to protect that brand.”
AUDITING FOR FOOD SAFETY
Everyone in the industry agrees that producing safe food requires a multi-layered approach that includes every participant in the food chain. FMI’s third-party certification program, SQF, offers yet another tool to that approach. “This program is intended for any company producing, manufacturing, or supplying food,” Hollingsworth explains. “It can be used by anyone in the food industry—from a farmer to a very sophisticated processing company.”
This certification has stringent controls and oversights in place. With the input of industry, the science community, and other experts, FMI developed the standard it expects all food companies to be able to meet. It includes food safety rules and regulations, best practices, and Codex and ISO standards.
“It is truly a certified assessment of how a company performs,” explains Hollingsworth. “It allows suppliers to use their certification as a tool to let their customers buying food from them know they are doing everything they can to produce safe food.” There are five of these programs globally and this is the only one of its type in the U.S.
Hollingsworth reports the FDA is supportive of this approach, having the industry take a leading role in voluntary certification programs to provide an additional layer of monitoring safe food along the chain. Under the SQF program, each facility must be audited at least once a year.
Munyon at AIB agrees there is no one formula to assure food safety and that an audit is one piece of that assurance, but it shouldn’t be the only piece. “I think it’s important to look at the risk profile of the products you are purchasing and to assure yourself that those risks are being examined by one element or another of the program.”
Regarding AIB’s audit of PCA in Q1 of 2008, Munyon reports it was a standard GMP (Good Manufacturing Practice) audit. “That audit was performed and delivered and at that time there were no major exceptions noted. What is not apparent through any audit is the disregard of information that comes to the management of a food facility that there is a problem. No audit could have prevented this, as an audit does not guarantee that the programs will be executed per the written documents. That was clearly the case with PCA.”
SAFETY GOING FORWARD
Capitol Hill has a number of ideas for legislation it is now floating from the food industry and government. One of particular note would invest the FDA with more authority than it currently has.
“There have been things coming out of the PCA situation that demonstrate the FDA lacks certain authorities that would have been beneficial—in this case identifying the problem before it became an outbreak,” reports Sundlof at the FDA. “At the present time, we can’t access critical records unless we can demonstrate there is a public health concern. So one of the things we will be discussing with Congress is having greater access to records before a harmful event occurs. Also, having direct authority to recall products would help prevent further illnesses.”
The FDA is also seeking authority to require food companies to have preventive safety and quality systems in place. “This would allow the FDA to audit a company to assure they have an acceptable system in place, that they are actually doing what their system calls for, and that they are keeping records of these activities,” explains Sundlof. Furthermore, the FDA wants to have a safety system in place that would look across the entire food supply chain, providing yet another layer of security.
Better control over the food supply chain will be a top priority going forward, promises Sundlof. “To the extent that the FDA can help, we will do that. In this case, PCA had auditors go out to certify that the plant was superior. This was the assurance the downstream companies were relying on and that system turned out to be a failure.”