Supply Chain Food Safety

The food industry must closely evaluate its extended supply chain to determine
where food safety gaps exist and to determine the best approach to fill them.
The supply chain is quite large with multiple nodes. A comprehensive strategy to
embrace the supply chain and develop a world-class food safety program
involves three discrete activities:
1. Assess: Assess the companys capabilities for preventing and responding to
food safety threats. This phase allows a company to benchmark itself against
leading practices in food safety. Even companies with mature food safety
programs can benefit from a comprehensive assessment, which identifies
capability gaps and helps set priorities for improvement. Once the improvement
opportunities have been prioritized, a roadmap for change can be developed.
2. Build: Build the governance, skills and systems to improve food safety
capabilities. During this phase, the company executes the roadmap. Typical
improvement activities include: developing appropriate leadership support for
food safety, elevating food safety objectives to the corporate level, implementing
new processes and systems to align with leading practices and training key
resources to support these changes.
3. Monitor: Monitor risks and trends on a regular basis, adjusting the food safety
program to address significant changes. In this phase, the company assesses
and improves the effectiveness of its food safety program on an ongoing basis.
As new threats to food safety emergeand as leading practices, standards and
regulatory requirements evolvethe company adjusts its food safety program to
address these changes.
One must take time to closely assess regulatory compliance, total management
systems, corporate policies, standards, training programs, second- and thirdparty audit programs and traceability. Figure 4 exemplifies how the application of
a diagnostic tool can assess the supply chain maturity level. Management can
then determine what must be done to make that particular node a core value
program.
The following recommendations may help proactive companies identify potential
gaps in food safety systems and implement improvements
Make food safety a top management priority
Define a vision for improving the organizations food safety capabilities
Hire the right people and leverage leading practices
Improve processes for crisis and incident management
Establish an effective performance measurement framework

An ongoing monitoring process helps ensure a consistent level of performance

and is critical for developing and improving an institutions food safety
capabilities.
Specific benefits:
Meet regulatory requirements and industry standards for transparency and
reporting
Reduce operational risk and annual losses
Provide a risk framework to support improved decision making
Benchmark compliance requirements against risks and performance goals
Provide insight about the true risk profile for individual organizations and
functions
Reduce redundancy in risk management and compliance activities
Enhance communication and assurance across the extended enterprise
As a company begins to address specific parts of the FSMA, it should consider
the following suggestions:
Reassess the corporate food safety culture from top management down to the
line worker and confirm it is properly supported with financial and human
resources, including training
Know how facility food safety and registration records are managed, accessed
and reviewed for regulatory and corporate compliance
Take a proactive approach with the regulatory agency with jurisdiction over
company facilities to ensure transparent and clear communications
Take time to meet with federal and state regulatory recall managers and share
how the company manages recalls as well as how the food safety systems are
managed
Confirm the registration of all facilities subject to the FSMA and know who has
the registration numbers and password access to the federal registration record
Track facility registrations and re-registrations reported to the primary person
responsible for ongoing compliance and protection of registration numbers as
well as the designated secondary backup person
Reconvene the companys food safety team and reassess all hazards across
the food safety system, upstream and downstream, including intentional and
non-intentional adulteration risks
Assess or reassess facility risk, based on the criteria outlined in the FSMA.
Internal, as well as third-party facilities, both domestic and foreign, should be
included in the assessment to fully understand the risks in the supply chain.

 Utilize subject matter specialists to characterize all products and facilities as

being high or low risk.

Closely review regulatory enforcement actions taken in the past 12 months for
all facilities within the company, including subsidiaries and the effectiveness of
the corrective actions implemented.
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