The time to modernize the food protection system as it prepares for the growing challenges and complexities of a global food supply is upon us. With the passage of the Food Safety Modernization Act (FSMA)—that mandates the integration of the food safety system and support for the development of a food protection training institute—the system is finally getting an overhaul.
With this overhaul comes a focus on the training needed to support the system. The benefits of improving the quality of regulatory work on the front lines are now considered a crucial part of a shared responsibility to protect the food supply.
The new focus on training has stemmed from ongoing concerns that technology has outpaced traditional regulatory approaches. Imports and fragile supply chains challenge regulatory expertise. Staff turnover in both federal and state food protection agencies has significantly diminished regulatory food safety knowledge and skill. This loss of institutional memory, coupled with the growing complexity of food production, processing and distribution systems, requires greater specialization of staff and new team approaches that cross traditional and jurisdictional boundaries.
As preventable foodborne outbreaks continue with rapid frequency, the cost of foodborne illness to the economy and the public’s health and confidence is a growing concern. Gaping holes in the food safety system are not a new problem. People from grassroots to government have been demanding changes to the current system for years.
The call to create a national integrated food safety system, supported by a national training academy, was made more than 12 years ago; neither ever materialized. Until now.
The Integrated Food Safety System and Why it Matters
The Integrated Food Safety System (IFSS) is a strategy of joining food safety efforts at all levels of government into one unified network.
For some time, there have been calls to create a single food safety agency to overcome the concern over seemingly inconsistent regulatory authorities scattered across multiple agencies. However, work had been steadily building in the food protection community to leverage the unique attributes of existing roles and responsibilities of government agencies using a cooperative approach.
The importance of bringing together the food safety resources and efforts of federal agencies, along with those of state, local, territorial and tribal food regulatory and public health agencies, was first identified by the Association of Food and Drug Officials (AFDO) in 1998 at a 50-state meeting hosted by the U.S. Food and Drug Administration (FDA). This alignment of agency efforts and resources was subsequently reiterated by FDA’s Deputy Commissioner for Foods, Michael Taylor, in a report from George Washington University;[1] and by the White House Food Safety Working Group in 2009.[2] The FSMA, which was signed into law in January 2011, lays the strategic groundwork for fully utilizing the IFSS.
Protecting the food supply is a multi-disciplinary effort that involves government at all levels. Over 3,000 local health agencies are recognized as our nation’s first responders to foodborne illness. City and county officials conduct illness surveillance and monitor the food supply by conducting inspections at restaurants and retail stores. State health and agriculture agencies conduct over 90% of the food safety inspections in food manufacturing facilities. State food laws are typically patterned after the Federal Food, Drug and Cosmetic Act, so these agencies have very similar authorities and responsibilities to those of FDA. However, many state and local agencies also have unique powers to take regulatory actions and to remove unsafe or unsanitary products from the market. In fact, these unique powers, duties and resources of the different agencies at each level can be leveraged through integration, close coordination and communication to increase the safety of foods.
In 2008, FDA once again brought together federal, state, local, tribal and territorial representatives to form a Partnership for Food Protection. Through a systematic approach, workgroups were formed to shape the vision for integrating government authorities in four areas: response to foodborne illness, coordinating risk-based inspections, improving communication systems and training.
Although state and local agencies conduct the overwhelming majority of food safety efforts domestically, FDA and other federal agencies monitor imported foods and create standards that ensure uniformity in food protection. As the U.S. food system is global in nature, an integrated food safety structure will provide a system to deal with food safety threats. Through collaborating and collectively sharing information as an integrated network, foodborne outbreaks and disasters will be controlled and contained more efficiently, and prevention strategies will be employed more effectively from “farm to fork.”
The Current State of Regulator Food Safety Training
A web search for “food safety training” yields courses offered by many companies, covering a variety of topics aimed mostly at food industry workers. In addition to traditional food science courses, many universities also offer courses and programs in food safety and food defense. However, these courses may not meet the job responsibilities of food protection professionals. Additionally, without federal funding, state and local agencies with limited budgets and staff will not be able to take advantage of such courses.
The FDA model Program Standards outlines suggested entry-level online training. However, a mandatory, career-spanning training curriculum for food protection officials to ensure capacity within federal, state and local agencies on a national basis does not exist. Additionally, there are no systems in place to ensure that all food protection training is standardized, properly formatted, peer reviewed, policy and regulatory compliant, meets quality standards and is updated on a regular schedule.
The estimated federal expenditures for training these professionals were less than $1M in FY2009.[3] Considering the roles and responsibilities of these food protection professionals, federal funding for training needs to be increased to meaningful levels.
“The biggest challenge we face in our job today is the ever-growing expertise we’re supposed to possess, with ever-shrinking budgets to get the training needed,” said Karla Horne, an environmental sanitarian for the State of Michigan. “If we’re not out there doing our jobs, there is no safety system.”
An Integrated Approach to Training
A critical component of the IFSS is training and certification. To be effective, the IFSS requires capable, knowledgeable and skilled professionals conducting comparable work at all levels—from entry-level to leadership. This workforce must consist of personnel involved in all aspects of food safety, including surveillance, compliance, laboratory analysis, epidemiological investigation and emergency response.
For this training and certification system to be successful, all food protection professionals must have a clearly defined skill set to do their jobs. They must routinely maintain and update their knowledge and skills in cutting-edge technology, emerging scientific issues, changes in laws, new regulatory requirements and global issues that impact the food safety system. This will ensure a consistent, uniform and quality workforce at all levels.
How does one compare quality and equivalency between food protection professionals at the federal, state and local levels? Shouldn’t an inspection of a food plant by a state agriculture inspector in, say, Georgia be performed to the same standard as an inspection done by an FDA investigator in California? Additionally, shouldn’t a local agency with the authority to embargo unsafe food be able to assert that authority based on the findings of a different agency in another state rather than duplicate lab testing?
To be able to rely on this type of coordinated effort, common standards need to be established—against which all employees must be trained. As adopted by the Partnership for Food Protection’s Training Workgroup, training and certification of food protection officials will be the foundation for the entire IFSS. It also will establish consistent best practices for data collection and inspections across federal, state and local agencies.
The existing FDA model Program Standards can form the basis for setting the bar that agencies must meet and against which they must be measured. The question then becomes, “What incentive is there for an agency to participate in the IFSS aside from a commitment to food safety?” Increased funding of state and local programs is always a good motivator. Measurable outcomes may lead to strategic decisions about shared federal funding. The FSMA identifies opportunities for more FDA grants and contracts for state and local agencies to support the IFSS.
Moving Integrated Training Forward Through IFPTI
In 2009, the Partnership for Food Protection Training Workgroup endorsed the training vision for the IFSS proposed by FDA.[4] This vision lays out a roadmap for a national training and certification system. Components include curriculum development, course delivery and quality standards for certification, auditing and funding. Also endorsed was the creation and support of the International Food Protection Training Institute (IFPTI) to serve as the hub for the national training network.
Seeing an opportunity to address the national food safety training problem, the W.K. Kellogg Foundation provided start-up funding to establish the IFPTI. In 2010, working with AFDO, and in conjunction with FDA through a cooperative agreement and Congressional funding, the IFPTI laid the groundwork for the training infrastructure for the IFSS (Figure 1).
Since its inception, the IFPTI began training food protection officials. More than 75% of the over 1,200 people trained throughout 2010 were federal, state, local, tribal and territorial regulators representing 47 states. Academic, industry and international representatives made up the balance. Recognizing the need for just-in-time training, the IFPTI partnered with the National Oceanic and Atmospheric Association (NOAA) and FDA to provide emergency training for regulators and industry to determine the safety and acceptability of seafood from the British Petroleum oil-contaminated Gulf-state area. This federal program provided hands-on training to develop skills in sensory detection for taint in seafood exposed to the oil. Those skills are critical for seafood safety monitoring in order for food protection officials to take regulatory response measures that can include advisories and the opening and closing of fisheries.
Working with federal regulatory and public health officials, the IFPTI is establishing and overseeing the implementation of a career-spanning national food protection training curriculum that will increase capacity and ensure competency and equivalency throughout all regulatory jurisdictions.
In its role as the lead training partner with FDA through a cooperative agreement, the IFPTI has been tasked with four major aims in the creation of a national integrated training system (Figure 2):
(1) Developing a training network for regulatory and public health officials using existing companies, universities, agencies and associations
(2) Serving as an administrative hub for the training network
(3) Developing and delivering standards-based training programs in line with the National Curriculum
(4) Building an instructor cadre to ensure the availability of highly trained instructors
Through a multidisciplinary curriculum team, the IFPTI is developing the first-ever National Curriculum for an integrated food safety system. As part of the curriculum teamwork, an inventory of existing food protection courses was created. Over 700 existing courses were identified and classified in content areas within the National Curriculum. This process led to identification of gaps in current course offerings.
To fill one of those gaps in the curriculum, the IFPTI developed a food protection Fellowship Program that provides future leaders from the state and local food protection community with an intense professional development experience. The program is a series of three week-long sessions divided into: (1) Law, (2) Policies, Strategies and Tools, (3) Labeling, (4) Evolving Science of Food Protection, (5) Food Systems Control Applications and (6) Prevention, Intervention and Response. Assigned mentors guide the Fellows as they complete projects that are presented at a poster session at the annual AFDO conference.
Industry also plays a role within IFPTI training. In keeping with the latest advancements in all areas of food protection, the IFPTI has enlisted the help of subject matter experts, instructors and Advisory Council members from food companies. Industry attendance is also encouraged in many of the regulatory training courses, and companies are offering their facilities and systems to serve as training grounds for regulators.
Aside from a training system, the FDA vision also calls for a separate certification system. The first step in developing professional certification is the performance of job task analyses. This process has begun using subject matter experts from food and feed agencies across the U.S.
Quality Matters
Strict adherence to established standards throughout the job task analysis, national curriculum design and certification processes is critical. Following the established standards instills validity and credibility in the job task analysis, curriculum development, training and certification processes.
Providing an integrated national training curriculum to ensure that food protection professionals acquire, retain and can apply essential knowledge, skills and abilities requires adherence to quality course and program design, delivery and assessment methods. Designing such an integrated training infrastructure requires efficient alignment of training opportunities, well-designed courses and materials, blended learning methods and instructors who have been trained to lead effective training events.
Creating and maintaining high-quality training requires strict adherence to standards created and accepted through transparent procedures and processes by the training community. Such standards have been established and are maintained by accrediting bodies such as the American National Standards Institute (ANSI), the International Association for Continuing Education and Training (IACET) and the International Organization for Standardization. Standards set and maintained by these organizations provide benchmarks by which accredited courses and programs are recognized as adhering to quality design and delivery measures.
The jointly developed ANSI/IACET 1-2007 Standard addresses processes for designing, developing and delivering continuing education and training, rather than the content of individual programs, which allows the standards to be applied across disciplines. Strict adherence to the established standards infuses credibility for course and program certificates for training in the career-spanning National Curriculum.
Course and program certificates provided by accredited training organizations indicate that the training attended was held to high-quality design and delivery measures. While course certificates provide evidence of attending training, program certificates indicate that training participants have completed an established sequence of courses designed to provide a well-defined set of knowledge, skills and abilities. These defined sequences of courses prepare professionals for independent third-party verification and credentialing, or certification, of their proficiency.
While training institutions focus on providing opportunities for training participants to acquire new knowledge, skills and abilities, certification is provided through third-party verification by organizations completely independent of the training organizations. This separation of the training organizations and verification officials ensures validity of the testing process. External verification of knowledge, skills and abilities, identified through the job task analysis, provides assurance that an individual has achieved a level of proficiency required for performance of her or his position.
Expanding the System Beyond Our Borders
Adherence to internationally accepted training design and delivery standards will help improve food safety and will provide common standardized training and certification that can be provided worldwide. Standardization of food safety expectations for countries that export to the U.S. will provide a new level of protection to the U.S. food supply.
The FSMA contains many new regulatory requirements—most of which will require training to some degree for industry and regulators alike. There are 17 areas of new training in the FSMA. The efforts already underway for creating the integrated training system will form the basis for expanding training beyond domestic borders.
The U.S. imports about 15% ($58 billion) of its food from outside its borders, including nearly 60% of the nation’s supply of fresh fruits and vegetables.[5] In addition, according to NOAA, more than 85% of all fresh and frozen seafood consumed in the U.S. is imported.[6] Numerous initiatives are targeting industry and regulators in other countries in order to ensure safer imports. Examples include the efforts of the Asian Pacific Economic Cooperation’s Partnership Training Institute Network, the Grocery Manufacturers Association and the Joint Institute for Food Safety and Applied Nutrition’s U.S.-based laboratory for training domestic and foreign food producers at the University of Maryland.
The use of third-party auditing organizations is also being relied upon to ensure the safety of imports. The National Curriculum being developed by IFPTI will lay the foundation for third-party auditor training, leading to individual certification and accreditation of third-party organizations.
Food for Thought
In the U.S., 48 million illnesses and 3,000 deaths occur annually due to food pathogens, and one out of every six Americans will develop a foodborne illness each year.[7] The cost of this to the United States is $152 billion per year.[8]
In addition to accidental contamination, the food and agriculture sector in the U.S. is extremely vulnerable to attack since we rely on an openly accessible global food supply. Biological agents delivered through our food chain would have devastating economic, health, social, political and psychological impacts. Training of those who regulate and participate in the U.S. food system offers the best solution for protection against contamination of the food supply and for maintenance of consumer confidence.
Protecting the public’s health through better training is the most cost-effective use of limited resources in these tight budgetary times.
The integrated training and certification system being built by FDA, IFPTI and the entire food protection community will be essential to ensure that all agencies have the capacity and competencies they need to fulfill their vital role in protecting the nation’s food supply. In our view, this training is simply that important.
J. Joseph Corby worked for the New York State Department of Agriculture and Markets, Division of Food Safety and Inspection for over 37 years. He is now the executive director of the Association of Food and Drug Officials (AFDO), a member of the Board of Directors for IFPTI and works as a part-time trainer for the National Center for Biomedical Research and Training at Louisiana State University (LSU).
Gerald Wojtala is executive director at the IFPTI. He is the past-president of AFDO, a member of the Institute of Food Technologists and a lead instructor with the National Center for Biomedical Research and Training at LSU. He holds a degree in microbiology from Eastern Michigan University.
Craig Kaml, Ed.D. received his degree in educational leadership from East Carolina University. He currently serves as the director of Curriculum Delivery for the IFPTI in Battle Creek, MI.
References:
1. Taylor, M. R. & S. D. David. 2009. Stronger partnerships for safer food: An agenda for strengthening state and local roles in the nation’s food safety system. Informally published manuscript, School of Public Health & Services, George Washington University: Washington, DC.
2. www.foodsafetyworkinggroup.gov/ContentAboutFSWG/HomeAbout.htm.
3. Congressional Research Service.
4. www.fda.gov/downloads/ForFederalStateandLocalOfficials/Meetings/UCM196248.pdf.
5. www.hhs.gov/asl/testify/2007/09/ t20070926b.html.
6. www.nmfs.noaa.gov/fishwatch/trade_ and_aquaculture.htm
7. www.cdc.gov/foodborneburden/2011-foodborne-estimates.html.
8. www.producesafetyproject.org/admin/ assets/files/Health-Related-Foodborne-Illness-Costs-Report.pdf-1.pdf.
Sidebar
Operating a Robust Retail Food Safety Training Program
With approximately 1,300 stores that comprise Food Lion, Bloom, Bottom Dollar Food, Reid’s and Harveys Supermarkets, the Food Lion Family is responsible for providing quality products in a fun and exciting atmosphere. An essential element to that quality is ensuring that a clear and effective food safety program exists and is supported by all associates.
The Food Lion Family takes pride in our food safety training programs. All associates are fully aware of our food safety standards and guidelines. They are also updated on changes to those guidelines and have the ability to ask questions throughout the process.
Multi-layer Training
There are several layers of formal training that take place with our retail teams. A combination of these methods gives us the opportunity to connect with all levels of associates in a specific way, depending on their roles and responsibilities.
Layer 1: Upon hire, all retail associates are required to review the entry level computer-based training module, which gives them the general expectations for keeping food safe in our operation. Areas discussed include personal hygiene, cross-contamination prevention and temperature control. Depending on their position and responsibility, new associates receive additional hands-on training within their respective departments.
Layer 2: Associates are then required to review an intermediate computer-based training module that provides food safety training by creating an emotional connection with the associate through storytelling. We have also developed an advanced level module that explains the importance behind time-temperature control, cross-contamination prevention, proper cleaning and sanitizing and good personal hygiene in depth. A new module will launch in 2011. Our goal is to update all training to support regulatory updates.
Layer 3: Our retail management teams are also required to achieve ServSafe certification. They are recertified a minimum of every 3 years and no more than 5 years, depending on the state in which they operate. We have a very strong team of approximately 40–45 ServSafe instructors/proctors throughout the organization who conduct this training.
Ongoing: In addition to the formal training, we provide a variety of task-based training aids, one-on-one training, vendor-supported training and corrective action trainings when needed.
This training strategy is continuously reviewed to ensure that we capture all associates and minimize any risks related to keeping the food we serve safe. We also collaborate with several departments to develop training materials, ensuring that all technical requirements are met and that associates receive accurate and timely training communications.
Effective Training Guidelines
• Begin with memorable, basic information.
• Explain why the training is important.
• Incorporate food safety into the organizational culture.
• Use effective training tools.
The tools you use will depend on the size of your operation. Larger operations with multiple sites may need to rely on technology for consistent training. Smaller operations may be able to train effectively using small group sessions. Whatever method used, make sure it is effective! Examples of training tools are the following: computer-based training, one-on-one training, in-house comprehensive quizzes, conference calls, task management tools, third-party vendor support, face-to-face meetings, demonstrations, training and job aids, formal food safety certification classes, email reminders and huddles. Never underestimate your power to encourage others on the importance of food safety.
Tips to Keep Food Safety in the Minds of Associates
Always be in the “monitoring mode.” You must always keep your eyes open for opportunities to praise as well as coach in the moment. In a busy operation, it is very easy for a food handler to forget what they have been trained to do.
Don’t just give them paperwork and never follow up. It shows that you are not interested, and they won’t be either! Always ask questions about what they learned from the food safety training initiatives. This follow-up conversation will help them to retain what they learned.
Monitor products, people, processes and tools. Always check to ensure that the proper steps are being followed and that recipes are being carried out per training guides; make sure all tools and surfaces are clean and sanitized and in good working condition.
Always lead by example! Employees are motivated to do the right thing when they see their leaders setting a good example.
A Shared Responsibility
A successful retail food operation must know, understand and realize that operating with food safety in mind is a business imperative, not an option. This means incorporating food safety training into annual budgets and equipping associates. Investing in training your employees gives them confidence to do their jobs right! If the goal is to maintain a competitive, sustainable retail food for the future, food safety training must have its seat at the decision table.
Food safety training is a shared responsibility by everyone in your organization. At the Food Lion family of stores, we make sure that every segment of development, training and communication is clear, concise and effective. Our associates are responsible for retaining and using the training provided. Associates are also encouraged to ask questions immediately if there is something they do not understand.
Chamus Burnside-Savazzini is the Food & Workplace safety manager, Food Lion Family with Delhaize America.
