Staying Ahead of Unexpected Risk

Just as you think you know the hazards associated with your product, it seems that a new one comes along.

In Legislative Update (page 50), David Acheson discusses preventive measures plants should be taking now to prepare for FSMA—despite the delays in its implementation. Included is what will be a requirement for processors to evaluate the hazards in their operations. While hazard analysis and risk assessment are fairly standard practice in the industry, it is also standard to set critical control points in the areas of greatest—most “critical”—risk. But, it is continually more difficult to differentiate levels of risk.

Who would have thought, for example, that a significant hazard for cantaloupe growers and processors would be Listeria? Or that the farm implicated in the 2011 outbreak would discontinue its entire cantaloupe program because that risk and liability had become too great. Who suspected that of high risk for E. coli in raw cookie dough would be its raw flour, not its eggs; or that the related 2009 outbreak would cause the hospitalization of 35 people?

More recently, the sighting of a mouse in or near your facility has become more than “just” a food-contamination hazard. With the summer’s rise in Hantavirus infections, for which the deer mouse has been implicated (See Rodent Risk Rises, page 18), there is also increased cause for concern about employee health risks.

In the column, From the Plant Floor (page 58), Bruce Ferree discusses the ever-increasing expectations of the quality department, from updated customer requirements to added federal regulation to changing third-party audits, noting that, “All these new and different things can put a crimp on our ability to manage the plant.”

Unfortunately, none of these necessarily address those newly, or not yet, exposed hazards and risks. As we’ve seen all too often, passing scores on third-party audits do not always mean that a food is safe or will not be subjected to a recall. In fact, a new paper¹ from food safety researchers at North Carolina State and Kansas State universities, argues that food safety audits need to be overhauled to protect public health. The authors note that, although auditing can be helpful in theory, “Audit reports are only useful if the purchaser who requires them reviews the results, understands the risks addressed by the standards and makes risk-reduction decisions based on the results. From past examples, there appears to be a disconnect between what auditors provide (a snapshot) and what buyers believe they are doing (a full verification of product and process).”

Evaluating and preventing risk has never been easy, and, unfortunately, despite technological and research advances, the unanticipated is too often becoming the highest risk. Ferree winds up his column by stating, “We all do our best … but sometimes it’s hard to keep up”; and asking what you do to keep up. We’d love to hear and share your insights on how you keep up with the system—and stay ahead of unexpected risk.

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

¹Powell, D.A.; Erdozain, S.; Dodd, C.; Costa, R.; Morley, K.; & Chapman, B.J. Audits and inspections are never enough: A critique to enhance food safety. Food Control (2012). doi: 10.1016/j.foodcont.2012.07.044.