.png?1652478248)
At a Thursday afternoon session during the 2022 Food Safety Summit, a panel of industry and regulatory officials discussed how food safety culture and behavior can contribute to modernization of the inspection process. The panel was moderated by Steve Mandernach, J.D., Executive Director at the Association of Food and Drug Officials (AFDO). Panelists included Patrick Guzzle, Vice President of Food Science at the National Restaurant Association; Roberta Wagner, Vice President of Regulatory and Technical Affairs at the Consumer Brands Association; Dionne Crawford, Manager of Restaurant Food Safety Field Partnership at McDonald’s; and Natalie Adan, Division Director of Food Safety at the Georgia Department of Agriculture.
Ms. Wagner, who previously worked within the U.S. Food and Drug Administration (FDA) and the U.S. Department of Agriculture Food Safety and Inspection Service (USDA FSIS), was the first panelist to express her thoughts on modernization of the food safety inspection process. Ms. Wagner began by explaining that large and some medium-sized food companies have corporate regulatory technical affairs teams that centrally develop and manage food safety-related programs and plans, to be implemented at the facility level. “Given the diversity of food companies, inspection programs need to be modernized to align more closely with current industry practices, and should be customized ... which means moving away from a one-size-fits-all inspection model,” she said.
With inspection customization in mind, Ms. Wagner advocated for a voluntary, two-tiered inspection approach. Tier one would involve a review of a company’s corporate plans by an expert FDA regulatory team. Tier two would ensure that centrally developed plans are being regulated with routine facility inspections. Under the current inspection model, “A large company with 100 facilities ... [could have its centrally developed programs and plans] reviewed by 100 different inspection teams for adequacy. This is not an efficient use of regulatory resources or industry resources,” Ms. Wagner said.
Ms. Wagner also remarked on the possibility of employing remote regulatory activities, guided by principles that encourage consistency from state to state, to enhance the efficiency of audits and inspections. Ms. Wagner also informed the audience that FDA has presented a package of regulatory proposals to federal legislators, which, if adopted, would revise the Federal Food, Drug, and Cosmetic Act to expand the agency’s scope of authority to conduct remote, interactive evaluations of food companies. Ms. Wagner closed her remarks by saying, “Inspection modernization will require fully embracing technology, preparing inspection reports that are streamlined, and include more structured data, as well as using new sources of data.”
Mr. Guzzle spoke next from the perspective of the restaurant industry. To Mr. Guzzle, inspection modernization has six components:
- Using the best, most advanced technological tools available
- Taking various sources of data from across sectors into account
- Comprehensive understanding of the FDA model food code and its annexes
- Standardization of inspection materials so that inspection results are consistent throughout states and local jurisdictions, and possibly sharing inspection materials with industry
- Improving industry culture of food safety
- Familiarity with and use of FDA’s Voluntary National Retail Food Regulatory Program Standards by health agencies and industry.
Following Mr. Guzzle, Ms. Crawford emphasized the need to make inspection success easy to achieve for industry with a simple, clear food code. “When we talk about modernizing the process, I think the first step is that you have to make it easy for people to succeed ... Modernization starts with a mindset, clarifying the target. It’s difficult to hit a target when it’s moving from state to state and jurisdiction to jurisdiction.” To clarify the target, jurisdictions and industry need to work together without cherry-picking. “We’re going to have to humble ourselves and realize, as jurisdictions [or as industry], we aren’t going to get everything we want.”
Another point that Ms. Crawford addressed was the importance of bringing retail and facility managers to the table when discussing modernization. “We spend a lot of time talking to ourselves about how to get other folks to do their job, when it is their job and they probably have a lot of dynamic ideas on how to get it done,” she explained.
Ms. Adan was the final panelist to speak her mind on inspection modernization. She emphasized points that her fellow panelists had previously mentioned, such as:
- Increased information and data sharing, including the use of a consistent approach that prioritizes structured data points rather than narratives
- Making better use of collected data, such as by leveraging software to track information and realize trends
- Using advanced technology to execute parts of the inspection process remotely
- Increasing stakeholder collaboration by developing relationships and open lines of communication, working together to reach consensus about goals and methods, and celebrating accomplishments together.
Discussion
After the panelists shared their remarks on inspection modernization, the panelists and audience engaged in a discussion about the topic. Mr. Mandernach began by asking the panelists for their thoughts on regulating food safety culture. Ms. Wagner stated that she does believe food safety culture can or should be regulated, but that FDA associates should be trained on food safety culture and understand what it looks like. She expressed her belief that messaging about food safety culture from Frank Yiannis, the FDA Deputy Commissioner for Food Policy and Response, has not yet filtered down to the field. A reluctance to engage in a collaborative partnership with industry still exists among inspectors, Ms. Wagner said.
Ms. Crawford added that she sees a regulatory application for food safety culture. “I would ask: Is there a culture of partnership? Of leadership? Are you building a culture of trust with the teams that you regulate?” She also suggested that inspectors and regulators could employ a softer approach in how they talk to industry representatives, and work on building trust with industry because sharing information about performance is “deeply personal.”
Ms. Wagner and Ms. Adan noted that the current state of the workforce—the “revolving door of employees”—makes it difficult to foster a solid food safety culture in both industry and regulatory bodies. Ms. Adan cited a 20 percent turnover rate of inspectors at the Georgia Department of Agriculture. According to Ms. Adan, most inspectors stay in their role “for two, maybe three years ... if we get [an inspector] for five [years], that’s great.”
The 2022 Food Safety Summit took place in person at the Donald E. Stephens Convention Center in Rosemont, Illinois from May 9–12.
