When Western Growers Association issued an announcement challenging the Food Safety Leadership Council and its demands for different food safety standards, it also pointed something out:
… the consortium has not provided the fresh produce industry with its own set of good handling practices that demonstrate that consortium members are properly handling fresh produce after receipt of produce from fresh produce suppliers.
In so doing, WGA raised a point that the Pundit has often been focused on, in pieces such as one you can read here in which we discuss the 12 links in the cold chain before it gets to the home of a consumer.
We also have been particularly concerned about the maintenance of temperature in retail cases, and we discussed a study that had been done right here.
When we ran a piece about the disgusting standards hotels have for cleaning glassware in hotel rooms as an example of the important role the buying end of the trade plays in food safety, we included these comments:
We know of not one single supermarket chain that is having its refrigerated cases third-party audited for maintaining proper temperature everywhere in the case, including during defrost cycles.
This led to some objections from several retailers who claimed otherwise. Here was a typical note from one retailer:
This is something our company does and has been doing for several years. We use a third-party company named Steritech to perform these audits. I can tell you that the management in the stores are always very concerned when they receive any negative feedback. Anything less than 100% compliance is frowned upon.
We were obviously interested to learn more about Steritech’s program, so we asked Pundit Investigator and Special Projects Editor, Mira Slott, to speak with this company and learn more about what it offers the trade:
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Chris Boyles, Technical Director of Retail, Food Safety Division Steritech Group Charlotte, North Carolina
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Q: Issues with food safety in the produce industry have intensified exponentially since the spinach E. coli crisis. Could you give us an overview of what your company does that can help our readers enhance food safety?
A: I work as technical director for retail and foodservice operations. We provide food safety services across wide sectors; upstream to GMPs, auditing of processing facilities, and further upstream to GAPs and farm audits. We work with more specialist niches for organic and HACCP plans; some folks want full blown vender certification programs for all food supplies sent to them.
Our reach is quite broad, also covering audits in slaughter facilities, how animals are held, etc. We have an integrated approach and we try to encourage all clients to take an integrated approach to food safety and understand their place in the chain.
We spend a lot of effort in continuing education. Our employees specialize in specific food safety areas, constantly expanding their knowledge and fulfilling the updated requirements for maintaining their professional certifications and food safety credentials. If you go to processing, we have experts in produce, seafood, canning, dairy and other categories. And the farming side gets very specialized. Food safety issues at retail vary in scale, but are reasonably defined areas, such as a case or cooler. When you expand to food safety issues in the field, the scope is extensive, where at retail food safety follows a pretty basic level.
Q: With much food safety attention being focused on agricultural practices in the fields, packing and processing plants, some suppliers feel retailers don’t do their fair part. To what extent do you work with leading retailers in their pursuit to bolster safety of their produce departments? In particular, what auditing/inspection services do you offer supermarket chains?
A: Steritech provides a comprehensive range of auditing services for a number of leading national and regional supermarket chains. Our core service at the retail level is food safety audits. We use the FDA food code as the standard. We work with clients that are mostly national, so the one standard applies across the company in all states. We cover all different areas, including temperature control, storage and protection, equipment and utensils, cleaning and sanitizing facilities from floors to ceilings, and personal hygiene practices.
The basic rules for food safety operating procedures are pretty standard. We focus a lot on personal behavioral practices. You really have to get down to what people are actually doing. Our approach is training clients to help educate staff and identify gaps so they can improve food safety practices.
Our auditors are specially trained to be trainers. They are not there to regulate. Most of our auditors have worked in a range of food service accounts covering both restaurants and hospitality and they can translate this broad experience to solutions for supermarket chains. Food safety is officially regulated by government. We help coach retailers on how to meet those requirements.
Q: Give us more details about your auditing methods. How do you measure food safety performance?
A: We have handheld computers for data capture when we’re out in the field. Sophisticated handwriting identification software translates to digital text. The ways to manipulate this data are endless. We can do customized reports for clients to help them evaluate their own data.
FDA identifies critical and non-critical food safety issues based on how likely the problem would lead to a food outbreak. Auditors assess and input where the critical problems are located. The ability to break down that data by regions and mine for specifics is very powerful, allowing retailers to focus on where they have the greatest risks.
Q: Could you share some examples of work that you’ve done; perhaps a case study or vignettes that demonstrate the need for your services and ways you helped alleviate or solve certain problems?
A: Most of our case studies are proprietary, but we do have broad scale conglomerate reports that give perspective. The company produces an Annual Audit Trend Report, which shows the benefits of having a food safety management system in place in restaurants and the need for regular audits to insure proper procedures are being implemented and followed. In the coming year, Steritech will be working to develop a similar report for the grocery industry, which will include results as seen against regulatory and industry benchmarks.
Q: What are the critical areas of concern?
A: The study evaluates the practices associated with seven major categories, five of which have been used by the FDA in similar studies. Data are grouped according to the U.S. Centers for Disease Control and Prevention’s ranking of those factors most commonly associated with foodborne illness outbreaks: 1) improper holding temperature; 2) poor personal hygiene; 3) inadequate cooking; 4) contaminated equipment; and 5) food from unsafe sources. In addition the study presents data in other critical and non-critical categories.
Q: Could you summarize the results?
A: Overall, audit data on food safety practices at over 800 restaurants shows improvements in nearly all areas. Notable results in critical areas include a nearly 40 percent decrease in the potential for contamination of food by reducing likelihood of cross-contamination between raw and ready-to-eat foods; 23 percent decrease in the number of violations resulting from improper hand washing practices; 30 percent decrease in the number of violations related to food contact surfaces and utensils being in good condition. Looking at non-critical violations, the study showed some 27 percent decrease in violations of potentially hazardous foods being thawed properly; 18 percent improvement in in-use utensils being properly handled and stored; and a 13 percent reduction in violations related to the proper stocking and condition of hand wash facilities.
Several other areas didn’t fair as well. There were a substantial number of violations for cold, potentially hazardous food being held at temperatures higher than 41 degrees F. In addition, the holding of hot potentially hazardous foods was an area in which violations actually increased. These results suggest that further worker education and management engagement are needed to correct holding temperature issues. Improper holding temperature is the Number One factor most commonly associated with foodborne illness, according to the CDC.
Hand washing and maintaining adequate hand washing facilities both remain important challenges for food establishments. However, education can play a significant role in reducing these types of violations. The study revealed a marked increase in several critical violations in later parts of the day. Improper holding temperatures topped the list, with both cold and hot food areas, increasing during audits performed in the lunch, afternoon, and evening time periods. The overall percentage of violations increased during later audit times in areas of hand washing, storage of chemicals, potential for contamination of food, and proper storage of clean utensils.
Q: Many of these issues seem applicable and relevant to supermarket chains. How do you get to the root of these problems during your auditing/inspection process?
A: Some most commonly cited issues at grocery stores are behavioral, related to processing on site in deli or in produce. Are employees handling foods with bare hands? FDA food code strongly discourages it. In general, most clients prohibit this with ready-to-eat foods. We’ll observe practices. Are employees healthy? Are they handling foods on dirty surfaces or handling raw foods and then handling cooked foods?
If we see something wrong, do they know the right way to do it? In the last few years, we’ve been incorporating process questions, rather than just observations. It helps us understand where the breakdown is occurring. Do they understand their internal requirements; sometimes they need a demo in the proper way to wash hands. Did they feel they didn’t have time?
Even when it goes to common issues of food surfaces not being cleaned, you have to break down what the actual item is, what are the specific issues there, is it an ice machine? Forty percent of restaurants had ice machines with build up. What are the procedures for cleaning, and is it done by staff or outside services? What filters are being used; is there a regular cleaning schedule? It may come down to specking a machine that is easier to clean.
The only way to get to the root cause is asking lots of questions. Unless you change the underlying behaviors, you won’t change the root cause. People hiring us voluntarily already have the motivation, which is different from a regulatory audit, being done whether you want it or not.
Q: Are these surprise audits or do the retailers and employees know in advance that you’ll be coming? How much does it matter to the validity of your inspections?
A: We are invariably announced. Some of our clients prefer they know in advance. First thing we do is check in with the manager, because we need to gain access behind the scenes. There is only a limited amount that can be seen from the front of a deli counter. We go to the back, open drawers, take temperatures in cabinets, and become very involved with the staff.
We’ve actually seen very little difference in scores of announced or announced audits. Folks tend to have the impression it will affect scoring. They may be more skeptical of the results. So there’s some perceptional value in surprise audits.
Q: How often do you do the audits and staff training? You say behavioral issues are at the core of many of these food safety problems. With employee turnover it must be a continuous battle for retailers to keep staff educated and committed?
A: The majority of folks ask for audits once a quarter, some more, some less. It depends what other programs the client has in place. We strongly encourage self-assessment programs. Obviously we can’t be there at all times. We can coach and guide, but they have to watch what’s going on every day. We teach nationally recognized food safety certification courses like the ServSafe program and FMI’s SuperSafeMark training, but it’s a constant challenge with turnover in the food industry to keep employees up to speed.
Q: How wide is the scope of the auditing? What areas do you cover in-store? Do you go to the backrooms and warehouses, to the loading docks?
A: To understand the crux of the problem, you need to examine all the outside influences. Was product taken care of properly before it came through their door? For standard supermarket audits we absolutely go to the backrooms and loading docks. If the retailer wants audits of distribution centers, we do those, but they involve separate types of audits on shipping and receiving, storing, temperature control, etc. The scope of auditing usually expands as they get involved in the program and prioritize by risks.
Q: Could you discuss specific issues retailers face regarding safety of produce, such as maintaining proper temperatures of different commodities in refrigerated cases and other merchandising displays? What impacts do you monitor in relation to the safety and quality of the product? For example, do you account for the product type, quantity, and the way it is stacked, rotated and merchandised on the shelves? Do you find that product is often cooler in the back of case versus the front of case, etc?
A: When we’re checking refrigeration in the retail environment, we are typically testing for product temperatures rather than case temperatures. The case would be secondary in our inspection to find root causes. If product typically needs to be at 41 degrees, we need to investigate why it’s not.
We would check air temperatures and examine if there are outside factors. There may be a spotlight shining down on an open case dramatically affecting that case temperature. Whether it’s a refrigerated case or walk-in cooler, we expect some variances in temperature.
Typically, we are looking to the worse case scenario. We’ll test product in the front of the refrigerated case, which is most exposed in the store, verifying the worse case scenario holding the minimum amount of refrigeration. For walk-in coolers, we have temperature testing in the warmest part of the unit.
For display behind the counter, we may have to start asking questions. When was product prepared, is it a human issue where product is sitting on the countertop too long before it’s put in the case? The problem may be mechanical or behavioral. Corrective actions are very different.
Q: Describe typical behavioral food safety problems in the produce department.
A: We’ve seen merchandising food safety issues. Cases are only designed to hold a certain level of product. If the employee exceeds it, the product probably won’t be able to maintain the proper temperature. Did a person overstocking understand the risk?
Training is very important. Our auditing team consists of full-time Steritech employees. We put our folks through extensive training, food microbiology, inspection skills, knowing where to look, and how to write the report with standard phraseology. When examining the food safety record at a location in Boston or San Diego, a national client needs the same consistent product. We monitor and follow up with our employees on a regular basis, and we conduct in-field calibration programs to insure consistency.
We also have training professionals on staff to train on training practices. You don’t get behavioral changes in food safety by leaving a report behind. You have to face the reality that food safety as important as it may be is only one aspect of the manager’s day. The retail store manager or produce department manager is focused on a thousand things, from the customer to the bottom line. We are there as food safety experts with both an objective eye and a targeted mission to expose food safety issues.
Q: Some of these behavioral food safety violations such as washing hands or operating on dirty surfaces, or touching raw product and then cross-contaminating cooked product don’t sound like rocket science to learn, discover or fix.
A: What might seem like an obvious safety violation could go unnoticed. In the same way, resolving a more complex problem could involve a simple fix. When you’re in the store every day, sometimes you don’t see what’s right in front of you, and you need a fresh set of eyes.
We have folks working in a wide range of environments, where they may have seen better ways to handle common problems. For example, employees in the preparation area may be working with quite a lot of product out on the counter at one time. They may be in the deli creating a salad and don’t realize how important it is that product not sit out a long time.
Temperature will rise dramatically and when put back in the case it takes a long time to get it down. The solution may be just a matter of batch processing, using smaller batches. Intuitively the most efficient way is to take more product out at a time, but in doing so, the employee, without realizing it, is creating a food safety risk.
Q: Your auditing report of restaurants showed a rapid increase in food safety violations late in the day. Could you point to other trends or scenarios that exacerbate food safety problems at supermarket chains?
A: Certainly rules of food safety don’t change, but things to watch out for in different scenarios might. During holiday times, more product comes in affecting storage. Walk-in coolers get so tightly packed it may be hard to monitor temperatures, and overstocked areas impact airflow and temperature levels. Employees are under additional pressure during very busy seasons. The temptation is to overstock the cases because so many people are buying product, but you do run the risk of abusing product. The same phenomenon can occur during promotion periods.
In a supermarket advertising campaign for St. Patrick’s Day, I witnessed raw corned beef and raw cabbage being cross-merchandised in the meat department. There is no guarantee these products will be jointly purchased and cooked together. Merchandising raw meats and vegetables together creates a risk of cross contamination. From an auditing perspective, maybe the product is located in a different department and the manager doesn’t deal with the cross-merchandising display. To get to the cause of the problem, it requires asking questions and interacting with employees because you can’t tell everything just by looking.
Q: Going back to your original premise that food safety requires an integrated approach throughout the supply chain, how important is consumer education in the puzzle? Do you get involved in helping retailers to educate their customer base?
A: There’s no doubt we get into consumer education on an ad hoc basis. Most consumers wouldn’t blame themselves. Protection of one’s brand involves educating consumers, whether talking to them directly on the retail floor or labeling packages or bags they’re carrying product home in. Some of this labeling is mandatory on items like eggs or meat.The problem is that most consumers don’t read it, unless it’s in large print, so having supplemental signage or food safety information is advisable. Actually, there are some requirements to post consumer advisory statements, which does fall into our inspections; if offering a raw or partially cooked product, you would need to advise the consumer it is undercooked.
Q: Engrained behaviors and well-established habits are not easy to shake. Some industry executives say that to make meaningful long-term shifts in management and employee food safety behavior, a company needs to delve deeper into changing the culture of its organization. Are you familiar with the food safety strategy at The Cheesecake Factory? They have tied bonuses and compensation directly to employee food safety performance. [Editor’s Note: to learn more about the innovative program, see Pundit’s Pulse of the Industry with Kix McGinnis Nystrom, vice president of kitchen operations here].
A: I agree with this premise that food safety must be a part of the company’s culture, and where audit program scores are being linked to bonuses and salaries.We encourage this further by advising companies to include food safety practices in job descriptions and that core food safety components are integrated as part of the job itself. Then it makes sense as part of job performance and employees’ evaluations.
With our clients — supermarkets, restaurants and hotels — integrating food safety into the company’s culture and all realms of the organization is certainly becoming more common. It’s a motivation factor to attach financial compensation to success in that area. Food safety is so critical to a company and its brand that it really only makes sense.
Q: Do you have any additional words of advice you can share with our readers to help them improve food safety?
A: There are a few pieces of guidance we stress.One is verification; check both yourself and your suppliers. Knowing where product is coming from and going to is critical. Monitoring goes along with verification. As much as we want to do for our clients, we can’t give them food safety on a visit.They have to monitor and self-assess and carry it out daily. That is the only way to protect their brand long term.
Food safety really has to become part of the culture. We have company presidents that actually sign a food safety statement to declare their intentions for the protection of their brand.
We think this kind of program is a great idea for retailers, far better than not doing anything or trying to do it oneself.
It is not quite the same as an audit of a grower or processor because the results are kept confidential. If a grower is GlobalGAP-certified or a processor British Retail Consortium certified, losing the certification is a very, very big deal. Here it is as big a deal as management wants to make it.
Still, having a firm such as Steritech physically in every store and DC every quarter is a significant financial commitment and speaks to a highly motivated retailer. So we would expect anyone who is doing it would, in fact, take the results quite seriously.
The key to success, though, is definitely cultural, and these large companies express what they truly value through their compensation plans. That is why the Cheesecake factory interview was so intriguing — they didn’t just do audits; compensation is affected by how the audits come out.
One can always quibble: maybe the FDA Food Code is not the right standard, maybe all audits should be surprise audits — at least at the front door of the store; maybe there is some conflict between doing auditing and doing training since to some extent the company is evaluating the success of its own training efforts.
The biggest problem, though, is probably that the companies really needing this type of assessment and training aren’t the ones that retain Steritech and other such organizations to do this important work.
Still, it is a great place to start and those chains utilizing these audit services should be applauded. Those who are not should be urged to start doing so. And when WGA needs to stand up for its members, maybe it can say to retailers: “We’ll show you our audit if you show us yours.”
Many thanks to Chris Boyles and the Steritech Group for sharing so much important information with the industry.
