[ October 8–11, 2019    McCormick Place    Chicago, IL USA ]

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Principles

One highlight of this year’s FPSA Annual Conference was the Food Safety and Sanitary Design Panel discussion, which featured food safety experts from across the industry. To continue the conversation, we spoke with John Butts, one of the panelists.

Butts has been in the food safety industry for more than four decades. He got his start at Land O’Frost, where he’s worked for 44 years. There, he was instrumental in working with the North American Meat Institute to put together workshops and serving on a task force on Listeria control. Today, Butts is still an advisor to the CEO at Land O’Frost as well as the President of FoodSafetyByDesign, a consulting firm he founded in 2010.

Challenges in tracing pathogen outbreaks

Over the course of his career, Butts has witnessed a significant increase in the ability to detect food safety problems and trace their source. This is due to the shifts to pulsed-field gel electrophoresis (PFGE) and then to whole genome sequencing (WGS). “We can now link, with a high degree of accuracy, the product, the environment, and the patient,” Butts explains. “The technological advancement has created a regulatory and technical tool that can be used to bring things together. If a processor isn’t able to effectively control the microflora in the plant, they might be linked to outbreaks over several years. This helps the regulatory and public health folks recommend the expansion of a recall.”

But, even WGS isn’t perfect, as we saw from the mysterious E. coli outbreak earlier this year that sickened more than 100 people before it was eventually traced back to ground beef. This speaks to the challenges of identifying the root cause of an outbreak and then tracing it back to a specific producer or production line.

“The challenge is the pathogen may not always be present,” Butts explains. By the time of testing, a leafy green, for instance, may no longer carry the pathogen. This was the part of the reason it was so difficult to identify the source of contamination in the recent outbreak of E. coli infections due to romaine lettuce. “The pathogen may come from contaminated water that was used in irrigation for a short period of time. But if that water magically gets cleaned up or they quit using it, things can change.”

Butts predicts that as food regulations evolve and new pathogen problems emerge, further improvements in detectability, traceability, and measurement systems will follow. “As our tools get better, our ability to control must exceed that.”

A principled approach to food safety

To prevent as many food safety problems as possible, Butts recommends sticking to principles — the American Meat Institute’s sanitary equipment design principles, to be exact. These principles are well known in the meat industry, but they’re just as applicable to other food sectors:

  1. All surfaces are cleanable on a microbiological level.
  2. Materials are compatible with the challenges of the environment.
  3. All parts are easily accessible without tools.
  4. There are no areas of product or liquid collection anywhere on the equipment.
  5. Hollow areas are sealed or eliminated.
  6. The equipment is free of cracks, gaps, and other niches.
  7. The equipment operates without creating unsanitary conditions.
  8. All controls include hygienic maintenance enclosures.
  9. The equipment is hygienically compatible with other plant systems.
  10. The OEM advises proven cleaning and sanitation practices for the equipment.

Butts notes the difference between principles and standards or specifications, namely, principles aren’t optional. “They’re things we shouldn’t violate.”

He explains: “Say you’re putting a hollow frame on a piece of equipment. You may be able to weld that perfectly in the manufacturing process. You may be able to use sophisticated precision controlled equipment. That's great. But all it takes is a problem and a maintenance man with a drill, and that great job that you've done may be quickly compromised.”

To avoid food safety being compromised in this way, Butts emphasizes the importance of training. “Sanitary design has to be part of our routine operational training,” he says. “We often hire maintenance technicians and mechanics from other industries. But how can we expect someone coming out of the automotive industry to understand sanitary design and equipment? We have to recognize the knowledge gaps that new workers may have and work to get them up to speed.”

This is best accomplished collaboratively. “I strongly encourage the formation of what I like to call a seek-and-destroy team,” Butts says. “This is made up of food safety, production management, maintenance management, engineering, sanitation — those folks working together to be held accountable for food safety from a sanitary operational standpoint.”

He also calls on OEMs to ensure their equipment is easy to clean, especially as it’s becoming more difficult to find workers to do sanitation tasks. “I think we would all, as manufacturers, love to see our suppliers advertising and delivering sanitary design at new levels.” He gives the example of equipment that can be disassembled without any tools.

The role of company culture in preventing food safety problems

“One of the things we've learned in the science of culture,” Butts says, “is that if you get the culture right, everything else will fall into place. Companies with significant employee engagement in preventive practices produce the safest product day in and day out.”

Many food manufacturers still take a fire-fighting approach to food safety, which makes it difficult for them to focus on prevention.

Butts outlines the tiered model journey toward an ideal food safety culture:

  • Doubt: At this point, plants are at a standstill and don’t believe they have any food safety concerns to address. They may be doing the bare minimum to meet regulatory requirements.
  • Awareness: Here, plants know something’s wrong, but they may not know what to do about it or how to get to the root of the issue. “We're just aware of it, and we inspect and test our way out of the situation,” Butts says.
  • Enlightenment: This is the “fire-fighting” phase. It describes companies that have recognized the problem and its cause, but they haven’t figured out how to solve it yet. “They’re just trying to solve the same problem over and over again.”
  • Prevention: When plants start developing interventions to eliminate the problem altogether, they’ve moved into prevention mode. Butts cites an example from the meat industry in the late ‘90s that involved cooking slicing machines to prevent contamination in niche areas. “We’d pick up a slicer with a modified forklift, take it to the smokehouse, and cook it,” he says. “This was an intervention that effectively removed the pathogen from the equipment.”
  • Prediction: “This is when I use analytics to tell me when I need to apply the intervention,” Butts explains. “This is where the economies of food safety really start hitting home because now I'm controlling my cost and I have a high degree of assurance in the production of safe product.”
  • Internalization: In the final step, preventive and predictive methods become an integral part of the business plan. “When I make food safety metrics a part of the business plan, I can reduce variation, reduce cost, and become a least-cost producer.”

For companies worried about the cost of implementing these measures, Butts says it actually saves money in the end. The savings come in the form of things like increased equipment efficiency, minimized product loss, and recall prevention.

But getting past the first step — acknowledging the problem — is perhaps the most difficult. As Butts concludes, “There has to be a recognition of the necessity for change and a desire to change.”

A look ahead to the future of food safety

As we move forward, Butts believes that measurement systems will get better, which means regulations will change. “Right now, we have problems detecting certain emerging pathogens,” he says. “We’re going to have to learn how to do that better. And as the systems improve to link things better, we’ll need to focus more on prevention. There have been a number of situations where we’ve linked environmental issues in a region to certain products coming out of that region. I think we’ll see more of that type of stimulus for greater regulatory controls. All they can do is ratchet down.”

To help processors and manufacturers improve their knowledge in this area, PROCESS EXPO will feature an extensive program of food safety training courses. Learn more about them and book your spot.