Food Safety Behavior: Catch the Culture

In this QA Special Report, based on exclusive interviews and the concepts of Frank Yiannas’ newly released book, Food Safety=Behavior (Springer, March 2015), QA looks at the evolution of the industry’s food safety culture from the perspectives of Hershey’s Vice President of Quality, Food Safety, Regulatory, Health and Industrial Safety Hugo Gutierrez and Maple Leaf Foods’ Senior Vice President of Operations and Chief Food Safety Officer Randall Huffman; reveals new insights on the regulatory aspects of a food safety culture from FDA Deputy Commissioner of Foods Michael Taylor; and provides a look behind the book and its applications at Walmart with Vice President of Food Safety Frank Yiannas.

Throughout the articles of this Special Report, chapters from the book are referenced that discuss the concepts applied by these prominent companies and how the degrees of influence across the industry are helping companies catch the food safety culture. (Chapter 18)
 

In 1998, the executives of the top beef processing companies of the U.S. presented an innovative concept, declaring food safety to be non-competitive and encouraging industry collaboration and knowledge sharing to enable companies to learn from one another’s best practices … and errors. It was the beginning of a new era that was, at least in part, a reaction to the 1993 “errors” of the Jack in the Box ground beef E. coli O157:H7 outbreak that sickened more than 700 people and killed four children.

Although the book wouldn’t be published for nearly 20 years, these executives were following a key point in Food Safety=Behavior by Walmart Vice President of Food Safety Frank Yiannas: “Errors – as much as we should strive to prevent them – should not simply be discouraged, punished, or ridiculed. They MUST be learned from, as they are a common route to true expertise, and more importantly, prevention.”

The concept is just one of the 30 easy-read, easy-application techniques of the book, each of which is dedicated its own chapter with concept, supporting research, application examples, and food safety implications. Each of which shows how food safety can be better caught in a food safety culture than simply taught in a classroom. The book is a follow up to Yiannas’ 2009 publication of Food Safety Culture: Creating a Behavior-Based Food Safety Management System, and answers the questions of “how”: imparting practical, proven techniques on how to establish this culture so employees catch onto, buy into, and comply with food safety behavior.

“In the five years since the publication of my first book, it has become increasingly apparent that people are interested in food safety behavior,” Yiannas said. “But they were wrestling with how to apply it. They wanted tactical examples.” As an aficionado of behavioral science, Yiannas has read hundreds of studies; those he found to be most influential and applicable to food safety behavior, he distilled down and applied into the 30 techniques of the book.

It should be fairly obvious to state that increasing food safety decreases the potential for contamination issues and outbreaks and increases regulatory compliance and brand protection. But as “food safety culture” becomes more and more a buzz-phrase of the industry, the development of a company-wide, behavior-based approach to food safety also becomes more of an industry expectation, economic benefit, and regulatory advantage.

 

The author is Editor of QA magazine. She can be reached at llupo@gie.net.

 

FDA: Culture Is a Preventive Control

As industry counts down to the first of the deadlines for publication of the final FSMA rules (in August) and awaits guidance, FAQs, and the specifics of the rules, FDA Deputy Commissioner for Foods and Veterinary Medicine Michael Taylor told QA that the existence of a food safety culture will have a positive bearing on a food facility’s regulatory compliance.

“We have zeroed in on this as an important part of our new compliance strategy in implementing FSMA,” Taylor said. FSMA is focused on prevention and companies being accountable for systems that actively prevent adulteration and contamination. “A company with a food safety culture is one that doesn’t just have food safety, HACCP, or preventive controls plans in name,” he said. Rather, it is active management with commitment at all levels.

“When you look at companies doing the best job, you do sense this idea of a food safety culture where it is a primary value of the company,” Taylor said. While it is critical that the culture diffuse through all levels, it has to be front of mind—and an overall mindset—at the uppermost levels of the company, with the investment of resources. “An element of it is leadership from the top that makes food safety a value,” he said.

And, Taylor added, “It’s a whole different mindset that can have a big positive impact on food safety performance and help us focus our efforts on firms that do not have strong food safety cultures.”

While Walmart’s Frank Yiannas may not have been the originator of the phrase “food safety culture,” Taylor sees him as having had significant influence on its evolution in the industry. “The work that Frank Yiannas has done is such critical leadership work,” Taylor said. “Frank is an exceptional person in the food safety landscape—he is a real food safety culture leader.”

A true, strong food safety culture will be evidenced by objective cultural indicators such as, Taylor said, Is the leadership knowledgeable? Is there expertise—evident in training and staffing? What efforts have been made toward high-quality private certification? “FDA is very science and fact driven, so we have to have objective indicators,” he said.

Thus, findings that show that a strong food safety culture is in place will indicate that the plant needs less regulatory time and attention. “You can sense when it is present,” Taylor said, “And we will take that into account as to how we inspect and how often we inspect.”

On the other hand, he said, if the inspector senses that you don’t have a food safety culture in place or aren’t implementing preventive practices, that, too, will impact the inspection. There are obviously some companies that are leading edge; some that want to be, but are not as advanced; and others that are not there yet—for whatever reason, he said. “We want to understand that and take that into account. That is how the industry’s food safety culture will be a factor in what we do.”

It’s like the theory of Social Norms (Chapter 4) vs. that of Broken Windows. (Chapter 7) That is, as explained in Yiannas’ book, “Compliance is proportional to the observed frequency of the desired behavior, [so] it is important to show the desired behavior as the social norm,” while “visible signs of norm violations such as disorder, disrepair [e.g., broken windows], and lack of cleanliness may elicit undesired behaviors as the norm in other and even more important compliance areas.” The concept demonstrates how subtle cues in the environment can influence a person’s behavior.
 

A Culture Change at FDA. FDA is not only focusing on food businesses and facilities in the evolution of industry’s culture. Rather, Taylor said, “We are also working to develop a different food safety culture within FDA.”

Noting that such a change is essential to the implementation of FSMA, Taylor said, “We have a dedicated, hard-working team that has been working around an enforcement model. Now we are working to reorient to be able to look at food safety compliance through a different lens—a public health outcome lens.” That is, does the firm’s system achieve a desirable outcome?

Just as changing the culture within a business or facility is not a simple change, nor will it be so within FDA. For example, he said, if a noncompliance is found during an FDA inspection that the facility can correct on the spot, it will be encouraged to do so. Exactly how the Agency does this is where it is working to evolve, Taylor said, but one key phrase that Taylor has repeatedly cited is: “We will educate before and while we regulate.” If inspectors find fundamental problems, processes, or hazards, they have to be able to direct the people to resources, such as guidance documents. “We don’t want to just mark it down, then go away, that’s not public health,” he said. “We have to provide resources—that’s the most rapid way of getting compliance.” And it’s a big shift for FDA.

That said, FDA is, in no way, abandoning the need to enforce regulations. The increased enforcement tools that FDA has been given through FSMA will enable it to act immediately to prompt change if needed to protect consumers. “We’re not here to punish, but if you have a problem that puts people at risk and don’t fix it, we will be very aggressive,” Taylor said. “The public expects us to document that the standards are being met, so it’s not just about finding and documenting noncompliance. That’s a big step upward in protection”

One way this will be fostered is through a more specialized field force. Rather than an inspector visiting a food facility one day, feed facility the next, and medical facility the day after, as had occurred in the past, inspectors will focus more on specific segments. FDA had previously been moving in this direction, but now, Taylor said, it will be formalized.

“It is a culture change within FDA that has huge implications,” he said, adding, “The thing that is so exciting to us—and reinforcing and motivating—is that nobody is fighting the need to do this.

“We believe that most companies want to do the right thing; they want to comply,” Taylor said. “The reason this approach works is because there is such fundamental strategic alignment which enables us to have people work together in a more collaborative component.

“We can’t force our way to food safety,” he said. “But when collaboration doesn’t work, we have other means.”
 

 

The Heart of Hershey

The Hershey Company has a simple vision: “Bring goodness to the world through great-tasting snacks…one smile, one moment, and one person at a time.” Food safety is an essential element of this vision, and it is not simply a responsibility of the food safety and quality assurance teams, or even manufacturing alone. Rather, it is at the heart of Hershey with every employee in every department educated in food safety to understand their specific roles.

Illustrated by a heart set within the iconic Hershey Kiss, the principle of “Food Safety: I own it. I live it.” depicts the commitment of Hershey and of each employee to keep food safety at the heart of all they do. (Chapter 20) But what makes it most powerful is that it is everyone doing it, said, Vice President of Quality, Food Safety, Regulatory, Health, and Industrial Safety Hugo Gutierrez. “The bottom line is that they are owning and living food safety every day and seeing everyone else doing it.” (Chapter 4)

It’s not simply a campaign, rather it is a part of Hershey’s drive to further enhance its food safety culture. “We recognized that we had a good food safety system at Hershey, but we wanted to move from good to great,” Gutierrez said. “And to be world class, you have to create a building platform.” To begin the journey, the team approached Hershey’s CEO, and executives explaining that they wanted to take Hershey to the next level. They not only detailed what the journey would do for the company, but brought in outside experts to speak on practical experiences of both the positive value of food safety and the adverse effects of errors.

By presenting both its importance to the company and a business plan, they were able to get the interest and commitment of the executive team to push an already high bar even higher, he said.

This executive buy-in and involvement is critical to improve one’s systems and build a world-class food safety culture, Gutierrez said. “The investment is different when you want to be more proactive.” For example, the company was not having problems with its labels, but it wanted to purchase a bar code-scanning system for further improvement; there was already a metal detector on the line, but the food safety team wanted to add an X-ray machine behind it. To make such noncompulsory improvements, Gutierrez said. “You have to have support first. If you have support, you find the resources.”

Such resources also include increased investment in its people, and “having the correct people with the correct knowledge in the correct places at Hershey,” he said. This includes the development of an internal regulatory group which interacts with industry groups as well as a focus on staffing and educators who are experts in adult training. Their objective is to change behavior to develop a behavioral-based food safety system.

In such training, Hershey’s does not stop at the plant floor to enhance food safety culture, rather, Gutierrez said, the company focuses on the education and commitment of all employees and suppliers. Whether one is in production, purchasing, engineering, R&D, or marketing, he said, “Everyone in the company will understand the concepts of food safety and our goals.” And, each will understand their own specific role. The company has developed general food safety awareness e-learning modules with department-specific e-learning currently under development. The training goal is to help each employee understand and commit to the concept and their own specific role. Every one of the videos (along with the “I own it. I live it.” principle) has been translated into five additional languages to ensure all Hershey employees around the globe can, and do, understand, own, and live their roles.

In addition to the heart in the principle’s logo signifying food safety being at the heart of Hershey, it demonstrates the need to extend a food safety culture by affecting people’s hearts, not just their minds, he said. Food safety education should not simply be dry training, but should include real-life experience, both of your own company and building off of other’s experiences—both positive experiences of joy and enjoyment of food, as well as negative experiences of tears and outbreak-responsible company officials being jailed. (Chapter 1)

Meetings are also held outside of Hershey with suppliers and their co-workers and “even, in some cases, competitors,” Gutierrez said. The company involves its supply chain, globalizing its system to ensure all suppliers meet the Hershey Standard and requiring that all be GFSI certified.

In its practices, Hershey also exemplifies Yiannas’ concept of lists. (Chapter 24) While checklists are, in general, not a negative thing, focusing too much on checking the boxes of a long and detailed “laundry list” can be counterproductive to actually instilling a culture. Rather, as Gutierrez said, Hershey strives to set key performance indicators (KPIs), prioritize needs, then completely focus on each priority before moving on to the next.
 

Food Safety=Trust. In distilling food safety down to its most basic aspects for consumer protection and loyalty and brand reputation, Gutierrez said, “Trust is everything; and food safety is a very integral part of that trust.” And, as reported by the National Confectioners Association, Hershey has that trust.

According to a survey of 80,000 shoppers, conducted by researcher BrandSpark International and Better Homes and Gardens and published in March, Hershey has been recognized as the most trusted chocolate brand.

The survey also showed that 70% of consumers place a high importance on established brand trust when purchasing a new product, and 63% say that it is extremely or very important that a new item they are considering for purchase comes from a brand they trust.

“So it makes sense, not just for food safety but for the business,” Gutierrez said. “It is a journey that probably never ends.”

 

Building Food Safety Into the Culture at Maple Leaf Foods

When a company is implicated in a foodborne illness outbreak that causes illness and loss of life, it can hide its head in the sand and hope it all blows over.

Or, like Maple Leaf Foods of Toronto, Canada, that company can step up to not only correct the cause but learn from the incident, publicly educate others on the lessons it has learned, and transform its own food safety culture. (Chapter 8)

It has been six years since the 2008 Listeria outbreak that resulted in 23 deaths, and six years since Randall Huffman was brought in from the American Meat Institute (AMI) the day after the recall to help the Maple Leaf team understand the root cause of the outbreak and work on an action plan. Today, Huffman is senior vice president of operations and chief food safety officer for Maple Leaf Foods.

“From Day One, I’ve seen an incredible commitment to change, and we have continued to improve,” Huffman said. “The thing that makes it work is that it is driven from the top down. CEO Michael McCain takes it personally every single day—I’ve seen it in action for over six years.”

And, from Day One, Maple Leaf has been highly visible, with McCain publicly acknowledging the issue, posting an apology, recalling all product from the implicated plant, shutting down the plant, and being a part of the solution while holding every employee accountable as well. (Chapter 30)

This accountability, and company-wide commitment to food safety, is a key change that Huffman has seen since 2008. “We spend time making sure everyone understands their role in food safety, and everyone in the business works really hard to understand and respond in a practical way.”
 

Company-wide Education. One aspect of this is the company’s two-day course on food safety. More than 1,400 senior managers and salaried plant workers have gone through the course, developed and taught by Maple Leaf personnel through the University of Guelph, for which Yiannas’ first book Food Safety Culture is a significant part.

“We give it to all our employees that go through our Food Safety Foundations training,” Huffman said. “It is a good reference text to go with our course because it really covers what we teach,” he said. “It teaches why food safety is important for everyone.”

To determine how well food safety has permeated the company, Huffman has coached his team to do more listening than talking. Listen to those who are not in food safety to see if they are asking the right questions; be a coach, but sit back and let others lead. For instance, when maintenance personnel are calling out food safety issues and people outside the food safety team are making sound food-safety related decisions, he said, “To me, that’s an indicator of success.”

It’s not easy, though, he cautions. “It’s hard to get people to have confidence in their ability to speak out. But when you get them to have confidence—that’s when the culture takes off.”
 

Learn from Others. While Huffman wouldn’t wish a similar incident on anyone, he realizes that building a food safety culture can be more difficult for those who haven’t been through a crisis. “I think for the average company that hasn’t been through a real traumatic crisis like ours, it’s harder to get people to pay attention to the importance of it,” he said. A road map of food safety had always been in place at Maple Leaf, but after the outbreak, everyone better understood the magnitude of food safety issues and really cared about building food safety. (Chapter 25)

“Since the 2008 tragedy, our approach has been to build food safety into the existing company culture, rather than create a ‘new food safety culture.’” Huffman said. “Companies must accept that the organization will have an operating culture that is deeply ingrained ... our approach was to imbed great food safety behaviors into the existing Maple Leaf culture.”

For companies who have not been through such incidents, Huffman said he would lean on learning from others who have, bringing in speakers, keeping it top of mind. Even at Maple Leaf, he said, there is a good percentage of people who have joined the company over the last six years, so, in some ways, he’s in the same boat. “I have to convince them, remind them of what happened.” Huffman writes an internal blog that helps to keep food safety—and the repercussions when it is lacking—prominent. He writes about significant food safety events in the industry to keep the profile high and keep people constantly thinking about what could go wrong with its own system or people.

Although the Maple Leaf outbreak was a major news event for a long period which could have had a devastating impact on its business, the primary reason the company was able to weather it was because it immediately took accountability for it. The company bought time on TV across the nation, and CEO McCain went on the air to accept fault and explain how the company would change because of it.

With this public admission and commitment to change, consumers were patient, Huffman said. They waited to see what Maple Leaf would do, and when the positive changes did indeed come through, they continued to purchase Maple Leaf products. Since that time, the food safety team has always had full support of its senior management for investing in food safety practices and technology it wanted to put in place.
 

A Cultural Norm. Today, food safety is a cultural norm of the company. “It really plays out at Maple Leaf because that happened,” Huffman said. But it is to help others build their food safety cultures—without having to go through a tragedy themselves—that the company is so vocal and public about the incident. “We believe that food safety is a non-competitive issue in the food industry and, thus, we have been very active in sharing our learnings and learning from others,” he said.

Huffman himself has given a number of talks on building a food safety culture. Each time, he said, “I open with the statement that 23 Canadians died as a result of products we produced. We’ve chosen not to run from it, but to accept it as a part of who we are today.”

Part of who Maple Leaf Foods is today is the commitment and buy-in by senior-most leadership of the company. “It has to be top down and bottom up to develop a culture,” Huffman said. “If I could boil it down to the difference between companies I’ve worked at where it worked and where it didn’t—that would be it.”

 

Walmart Looks at Culture Through a Different Lens

We all know that your appearance, including clothing, can impact others’ perception of you, but did you also know that it can influence your own behavior? Studies conducted by two behavioral scientists confirmed the concept of “enclothed cognition.” For example, in a study cited in Chapter 2 of Food Safety=Behavior, when participants were given a cognitive task, those who simply wore their own street clothes made almost twice as many mistakes as those who were provided with lab coats to wear during the task.

The concept is one of author Frank Yiannas’ favorites, as it causes us to look at behavior and clothing through a completely different lens, he said. “People are inclined to behave differently because of what they have on.” As such, the concept has been applied to the uniforms worn at Walmart, where Yiannas is vice president of food safety.

In the food processing plant, worker clothing has always been important—but the purpose was to prevent contamination. From the thought-provoking results of the studies, Yiannas recommends that plants consider if enough thought is being put into what dress codes mean to food safety—beyond simple cleanliness. Could food safety be improved by a change of dress code, ensuring clothing/uniforms are maintained in a clean state, and implying expected behavior through clothing?

The Broken Windows theory (cited in the FDA article, page 11) is another of Yiannas’ favorites, as is “Birds of a Feather” (Chapter 12), a concept of homophily which is extensively incorporated at Walmart. The concept says that, just as “birds of a feather flock together,” so, too, do people with similar characteristics or interests tend to spend time together—and be influenced by one another.

“In food safety, we have historically gotten things wrong,” Yiannas said. Most frequently companies use the CEO and other prominent people to convey messages when they should be using front-line employees with whom the workers can relate. This is applied at Walmart in its educational “Mr. Rollback” videos, created to communicate and reinforce food safety practices. In the videos, which use instructive humor, Mr. Rollback is Darrell, a real employee. The practice, which could be applied across the food supply chain, employs research findings that suggest that, as Yiannas cites in his book, “we might be more effective by having the message delivered by an employee within the workplace who is familiar to their colleagues and occupies a similar position.”

Similar applications of behavioral study results can be seen throughout Walmart’s food safety education and processes. One significant area is the application of “error-based training.” (Chapter 8) “We teach ‘the right way every day,’ but we also teach the wrong way and its consequences,” Yiannas said. For example, when training an employee on the cooking of rotisserie chicken, real-world examples are shown of cross-contamination, such as fresh vegetables contaminated by raw chicken juices, and resulting outbreaks and issues are discussed. In this way, workers are not simply learning what they need to do, they are being educated on why it is important. “From an authoritarian point of view, we may underestimate or forget the importance of why,” he said.

Teaching by learning from the errors of others is a great tool, Yiannas said, adding that, across the industry, “we have to get better at investigating outbreaks and teaching from the mistakes.”

Since Yiannas joined Walmart in 2008 (prior to which he was director of safety and health for Disney), “it has always been about continuous improvement of what we’ve done and how we can make it better,” he said … both within Walmart and throughout its supply chain.

While many of its supplier requirements were more general in the past (e.g., its GFSI requirement), Yiannas sees future requirements as becoming more focused. “That’s the future of food safety at Walmart—more product and commodity focused,” he said. For example, “How do you further enhance the safety of a product that has repeatedly been an outbreak vehicle?” Citing produce, he said, “We think the produce supply, in general, is safe, but things still happen because there is not a solid kill step.”
 

The Food Safety Culture. While applying individual concepts can help to increase specific food safety practices, the ultimate goal should be to influence behavior as a whole to develop a full food safety culture across your entire business and supply chain. Providing easily applied methods to do so, that take little effort or cost, was exactly Yiannas’ intention in publishing Food Safety=Behavior. And the techniques are based on practices that have been successfully implemented at Walmart and elsewhere.

“My #1 job at Walmart is to be the greatest food safety culture advocate in the whole organization,” he said. “But I can’t be everywhere or even have a team that is everywhere. The only way is to create a culture of food safety to influence the behavior of others.”